From Culture to Liability: How the New NR-1 Changes Risk Assessment

The update to NR-1 introduces a significant shift in how companies must approach occupational health and safety, particularly in relation to the management of the work environment. 

The main point of attention is the inclusion of so-called psychosocial risks. In practice, this means that issues such as pressure for results, excessive workloads, communication failures, internal conflicts, and leadership style are now treated as formal occupational risks. In other words, these topics are no longer viewed merely as matters of workplace climate or management, but instead require structured treatment within the company’s internal processes.

For companies, the impact is direct: it is no longer sufficient to rely on isolated policies or initiatives. Organizations must now be able to demonstrate that they have a consistent process for identifying, assessing, and monitoring these risks.

The core of the regulation is not to eliminate problems, which would be unrealistic, but to ensure that companies are aware of their risks and actively manage them in an organized manner. This represents a shift in focus: instead of looking only at events (such as an employee complaint or medical leave), the emphasis moves to how the company manages its work environment.

In this context, documentation becomes strategically important. The Risk Management Program (PGR) must accurately reflect the company’s reality, clearly recording identified risks, the measures adopted, and the monitoring of these actions. Any inconsistency between documented policies and actual practice is likely to become a key point of scrutiny in inspections and legal disputes.

Another sensitive aspect is the diagnostic process. The regulation requires companies to understand, in a structured way, how work is organized. This involves analyzing objective data, such as absenteeism, turnover, health-related leave, and workplace conflicts, rather than relying solely on subjective perceptions. Without this level of assessment, any action plan is likely to be weak.

A common misconception already emerging in practice is treating the issue solely as a well-being initiative. Programs offering psychological support, benefits, or engagement activities are positive, but they do not address the problem if its root causes lie in how work is structured. The expectation of the regulation is precisely that companies address the source of the risks, not just their effects.

From a legal perspective, this is a key area of concern. The absence of proper risk management may give rise to claims for moral damages, recognition of occupational illness, job stability, and even collective claims. In addition, there is a clear trend toward stricter labor inspections, particularly regarding the alignment between formal policies and actual practices.

Another important point: formalizing processes without implementing them may be worse than not formalizing at all. When a company documents risks but fails to demonstrate effective action, it may inadvertently create evidence against itself.

For this reason, compliance with the updated NR-1 should be viewed as an ongoing process. The safest approach involves building a consistent diagnostic framework, integrating internal areas (HR, legal, occupational health and safety, and leadership), and establishing a routine for effectively monitoring the measures adopted.

More than a regulatory obligation, the new NR-1 reflects a shift in expectations: companies will be assessed not only based on what happens in the workplace, but on how they manage it. And it is precisely this management that will determine the level of legal protection, or exposure.

The recommendation is to anticipate this shift and address the issue strategically, rather than making reactive adjustments later on.