Brazil’s NR-1 and psychosocial risks: is HR ready to see what the company can’t?

Even with fines suspended, the obligation to identify and manage psychosocial risks remains in force. Here is the current picture and how HR can get organized

Brazil’s NR-1 (the national occupational health and safety regulation) now requires psychosocial risks, such as overload, conflict, harassment and lack of autonomy, to be part of Occupational Risk Management (GRO) and the PGR (risk management program). Identifying these risks is the norm’s biggest challenge, because they rarely show up in a single metric. And the enforcement pause is no reason to wait: the cost of inaction tends to exceed the cost of any fine. For multinationals, a Brazilian subsidiary without documented compliance also carries reputational and litigation exposure that can reach headquarters.

Fines suspended, obligation maintained

In June 2026, Justice André Mendonça of Brazil’s Supreme Court (STF, case ADPF 1316) suspended for 90 days the enforcement of fines and sanctions tied to specific NR-1 items on psychosocial risks. The full court upheld the decision unanimously and, in September, the suspension was extended for another 90 days while the matter is discussed in conciliation at the court. Sources differ on the end date (December 2026 to January 2027), so it is worth following developments.

The key point: the suspension covers penalties, not the regulation. Companies are still required to identify, assess, address and document these risks in the PGR. Individual labor lawsuits over illness, harassment and workload are not affected.

What the Ministry of Labor expects from companies

According to guidance from Brazil’s Ministry of Labor and Employment (MTE):

• Psychosocial factors must be addressed in the Preliminary Ergonomic Assessment (NR-17), integrated into the GRO, including remote and hybrid work.

• The company chooses the methodology and the person in charge, as long as they have adequate technical knowledge. Questionnaires are optional and are not enough on their own.

• There is no mandatory national checklist. Labor inspectors assess the technical consistency and coherence of the process.

• The risk inventory must be dated and signed, and the action plan must set out measures, owners, deadlines and follow-up.

• Employee participation must be effective and ongoing, not merely formal.

• The assessment must be reviewed at least every two years, or sooner if relevant changes occur.

How HR can identify what doesn’t show up

• Use multiple sources: one manager’s perception or a single survey is not enough. Combine employee listening with data on absenteeism, turnover, overtime, leaves of absence and engagement.

• Cross-reference indicators (people analytics): overtime concentrated alongside rising turnover, for example, shows where to look. Data points the way but does not explain on its own what is happening.

• Work with occupational health and safety, leadership and employees: the more an analysis depends on one person, the greater the risk of underestimating factors.

• Make the process recurring: regular surveys, interviews and indicators allow you to track how risks evolve, even through team or management changes.

Why not wait

In 2025, Brazil’s social security agency (INSS) recorded 166,489 temporary disability benefits linked to anxiety disorders and 126,608 for depressive episodes, and the Ministry of Social Security reported a record 546,000 mental health leaves. These figures cannot be attributed solely to the workplace, but they show the scale of the problem. The same process that demonstrates compliance can also reveal overload and a deteriorating climate before they turn into leaves of absence and lost productivity.

Conclusion

NR-1 should not be treated as a task to avoid fines, but as a continuous process of identification, assessment, treatment and monitoring. Companies that start now, with method, listening and data, will be ready when the suspension ends and will protect both people and results.

Sources: Opinião RH, Ministry of Labor and Employment (MTE) and Contábeis | Adaptation and review: DBS Partner Team

Absenteeism, overtime, leave and turnover data live in payroll and HR routines, and organizing them accurately helps spot risk signals earlier. DBS Partner runs your company’s payroll and HR routines with reliability and compliance. Get in touch with our team and find out how we can support your company’s HR. Email us at dbs@dbspartner.com.br.