NR-1 and Psychosocial Risks: What Changes for HR?

Since May 26, 2026, the new version of Chapter 1.5 of the NR-1, which now expressly includes work-related psychosocial risk factors within the scope of the Occupational Risk Management (ORM). :contentReference[oaicite:1]{index=1}

In practice, this underscores the need for organizations to identify, assess, and manage risks related to the organization and working conditions that could affect workers’ health.

Examples of work-related psychosocial risk factors include situations such as:

• Work overload;
• Excessive demands;
• Harassment;
• Lack of support;
• Problems related to work organization;
• Conditions that may contribute to work-related illness.

The Ministry of Labor and Employment itself has published specific materials to guide organizations on the implementation of the GRO/PGR and the management of psychosocial risk factors. :contentReference[oaicite:2]{index=2}

In this article, you will understand What changed in NR-1 in 2026, what psychosocial risks are, what companies need to do, how to document their actions, and how to turn this new requirement into a more mature management framework.

What changed in NR-1 in 2026?

The main change relates to the revised wording of Chapter 1.5 of NR-1, which now explicitly addresses work-related psychosocial risk factors within the framework of Occupational Risk Management.

According to the Ministry of Labor and Employment, the GRO should cover the various occupational hazards and risks present in the organization, including those related to psychosocial factors in the workplace. :contentReference[oaicite:3]{index=3}

The new wording took effect on May 26, 2026, following the extension established by MTE Ordinance No. 765/2025. :contentReference[oaicite:4]{index=4}

This means that organizations need to take these factors into account within their occupational risk management framework.

What are work-related psychosocial risks?

Psychosocial risks are related to factors within the organization, as well as the conditions and manner in which work is performed, that can contribute to negative impacts on workers’ health.

NR-1 focuses on work-related risk factors, rather than making individual clinical diagnoses.

Some examples cited by the Ministry of Labor and Employment include:

• Work overload;
• Harassment of any kind related to work;
• Lack of support;
• Problems with work organization;
• Excessive demands;
• Unsuitable working conditions.

The MTE Guide emphasizes that these factors should be incorporated into the organization’s occupational risk inventory. :contentReference[oaicite:5]{index=5}

Are psychosocial risks the same thing as mental health problems?

No.

This distinction is important.

The management of psychosocial risks as set forth in NR-1 relates to the identification and management of workplace factors that may contribute to health risks.

The goal of occupational health management is not to diagnose mental illnesses in workers.

The focus is on understanding working conditions and work organization and identifying situations that need to be prevented or controlled.

That is why a company should take a look at its work environment and ask:

“Are there organizational conditions that could create or increase health risks for workers?”

What are some examples of psychosocial risks in the workplace?

Risks may vary depending on the industry, business activity, and specific circumstances of each organization.

Examples that can be considered include:

• Work overload;
• Excessive demands;
• Excessive pressure;
• Lack of autonomy;
• Lack of support from leadership;
• Harassment;
• Recurring conflicts;
• Lack of clarity regarding responsibilities;
• Communication problems;
• Inadequate organization of activities;
• Lack of support in the workplace.

It is important to note that the existence of a particular situation does not automatically mean that there is a significant risk. The organization must conduct a proper assessment, taking into account its context and actual working conditions.

Why did psychosocial risks come to the forefront in NR-1?

The update to NR-1 reinforces a broader view of occupational risk management.

Occupational health and safety do not depend solely on physical or chemical hazards or accidents.

The way work is organized can also influence workers' exposure to risks.

Therefore, management needs to consider factors related to:

• Work organization;
• Requests;
• Relationships;
• Autonomy;
• Support;
• Conditions for carrying out the activities.

The MTE itself highlights the explicit inclusion of work-related psychosocial risk factors in the GRO as one of the main changes in the revision of Chapter 1.5. :contentReference[oaicite:6]{index=6}

What is GRO?

GRO means Occupational Risk Management.

It is the framework used to manage occupational hazards and risks within the organization.

Management must be ongoing and must adapt to changes in working conditions and work organization.

The Ministry of Labor and Employment recommends that risk management be integrated into the organization's activities and reflected in documents and processes related to occupational management. :contentReference[oaicite:7]{index=7}

What is PGR?

PGR means Risk Management Program.

The PGR is used to implement the organization's occupational risk management.

Management-related elements include:

• Hazard identification;
• Risk assessment;
• Risk assessment;
• Preventive measures;
• Action plan;
• Monitoring of the measures.

The PGR must continuously monitor the company's activities and take into account any changes that alter the nature of occupational risks. :contentReference[oaicite:8]{index=8}

How are psychosocial risks incorporated into the PGR?

Work-related psychosocial risk factors should be taken into account as part of the occupational risk management process.

In practice, the company must assess whether there are any work-related situations that pose risks and, when necessary, implement preventive and control measures.

The process might follow a logic such as:

Identification → Assessment → Classification → Prevention → Control → Monitoring

This information must be consistent with the reality of the organization.

How can you identify psychosocial risks?

There is no single tool that works for all companies.

The methodology should take into account the context, processes, and characteristics of the organization.

Sources of information that can help with identification include:

• Observation of working conditions;
• Process analysis;
• Interviews;
• Listening to employees;
• Questionnaires;
• Internal indicators;
• Incident reports;
• Data on absences;
• Occupational Safety and Health (OSH) Information;
• Records related to complaints and disputes.

The MTE advises that inspections may take into account, in addition to the GRO/PGR documentation, the actual working conditions, interviews, records, and other elements of technical verification. :contentReference[oaicite:9]{index=9}

Is worker participation important?

Yes.

Identifying risks related to work organization can benefit significantly from the workers’ own perspectives.

People who perform a certain task on a daily basis may identify situations that do not always appear in formal documents or procedures.

Therefore, a mature management team can use mechanisms to:

• Listen to workers;
• Identify problems;
• Record observations;
• Analyze recurring situations;
• Evaluate preventive measures.

Management should take into account actual working conditions, not just what is described in the documents.

Does the company need to create a specific document on psychosocial risks?

It is incorrect to view the update to NR-1 as an obligation to simply create a new, standalone document called a “psychosocial risk report.”.

The key point is to integrate work-related psychosocial risk factors into the process of Occupational Risk Management.

The MTE emphasizes that compliance depends on the consistency of the process used to identify, assess, control, and manage risks. :contentReference[oaicite:10]{index=10}

Therefore, the company should avoid a purely documentary approach.

What matters is demonstrating that the risk was identified, assessed, and addressed in a manner consistent with reality.

What documents should the company review?

The required documentation depends on the context and structure of the organization.

As a starting point, the company should assess whether it needs to update:

• Risk assessment;
• PGR;
• Action plan;
• Occupational Safety and Health Procedures;
• Evaluation records;
• Preventive measures;
• Evidence of implementation;
• Follow-up records.

The documentation must reflect the actual risk management process.

What measures can be used to address psychosocial risks?

Measures must be determined based on the identified risks.

Depending on the situation, they may involve:

• Process reorganization;
• Appropriate allocation of tasks;
• Improved communication;
• Review of responsibilities;
• Leadership training;
• Measures against harassment;
• Strengthening communication channels;
• Improved support for workers;
• Monitoring recurring situations.

The goal should be to address the work-related factors that create or increase exposure to risk.

What can the inspection verify?

This is one of the most important points for companies.

According to the guidelines issued by the Ministry of Labor and Employment, inspectors may examine:

• GRO/PGR documentation;
• Risk assessment;
• Methodology used;
• Actual working conditions;
• Interviews;
• Records;
• Preventive measures;
• Consistency between documents and reality.

The MTE clarifies that, to date, there is no single, exclusive national checklist for monitoring psychosocial risks. The assessment generally takes into account the applicable regulatory requirements and the technical consistency of the process adopted by the organization. :contentReference[oaicite:11]{index=11}

Is there a learning curve for companies?

With the entry into force of the new provisions in May 26, 2026, the MTE stated that, for the new provisions of NR-1 related to psychosocial risk factors, the “double visit” criterion applies, initially for guidance purposes.

According to the Ministry’s own Q&A document, during the 90 days following the effective date, enforcement efforts will focus on providing guidance, instruction, and notification to organizations regarding the need to comply with the new requirements, without prejudice to the appropriate administrative measures in applicable cases. :contentReference[oaicite:12]{index=12}

This should not be interpreted as an exemption from complying with the rule.

Companies should use the orientation period to review processes, identify gaps, and implement the necessary measures.

How can a company prepare for NR-1 in 2026?

A structured preparation process can follow a few steps.

1. Conduct an assessment

Evaluate how the company currently manages occupational risks.

2. Review the risk inventory

Verify that work-related psychosocial risk factors have been adequately addressed.

3. Evaluate the methodology

Verify that the method used to identify and assess risks is consistent with the organization's actual circumstances.

4. Listen to the workers

Develop appropriate mechanisms to understand workers' perceptions of working conditions and work organization.

5. Identify gaps

Compare the identified risks with the existing controls and preventive measures.

6. Create action plans

For each significant deficiency, identify the responsible parties, deadlines, and corrective actions.

7. Document the actions

Keep records that demonstrate that the measures have been implemented.

8. Monitor continuously

Risk management must keep pace with changes in the organization and in working conditions.

NR-1 Checklist and Psychosocial Risks

NR-1 and Psychosocial Risks: What Changes for HR?

Managing psychosocial risks requires coordinated action among different departments.

HR can provide information related to:

• Work organization;
• Training;
• Organizational climate;
• Conflicts;
• Absenteeism;
• Turnover;
• Leadership management;
• Internal policies.

However, occupational risk management should not be treated as the sole responsibility of HR.

It is an activity that involves the structure of Occupational Safety and Health and must be integrated into the organization's risk management.

NR-1 and psychosocial risks: What is the relationship with compliance and GRC?

Although NR-1 pertains to Occupational Safety and Health, its implementation involves various elements typical of a governance and risk management framework.

An organization needs to:

• Identify requirements;
• Assess risks;
• Define controls;
• Record evidence;
• Create action plans;
• Track deadlines;
• Monitor indicators;
• Demonstrate compliance.

This cycle is very similar to the one used in other areas of GRC.

That's why a management platform can help integrate information and prevent each department from working in isolation.

How can Triskle help with managing NR-1 requirements?

A Triskle GRC It allows you to organize processes related to the management of requirements, risks, controls, evidence, and action plans in a centralized environment.

For an organization that needs to track its progress toward compliance with NR-1, a GRC framework can support processes such as:

• Recording of regulatory requirements;
• Risk identification;
• Control management;
• Centralization of evidence;
• Recording of nonconformities;
• Action plans;
• Designation of responsible parties;
• Tracking deadlines;
• Metrics;
• Executive dashboard.

This helps make regulatory compliance an ongoing and traceable process.

Instead of discovering a vulnerability only during an audit, the company can monitor its development before the problem escalates into a major incident.

Frequently Asked Questions About NR-1 and Psychosocial Risks

When did the new NR-1 on psychosocial risks take effect?

The new wording of Chapter 1.5 of NR-1 took effect on May 26, 2026. :contentReference[oaicite:13]{index=13}

What changed in NR-1 in 2026?

The new wording now expressly includes work-related psychosocial risk factors within the scope of Occupational Risk Management. :contentReference[oaicite:14]{index=14}

What are psychosocial risks in the workplace?

These are factors related to working conditions and work organization that can contribute to health risks for workers, such as work overload, harassment, and a lack of support.

Should psychosocial risks be included in the PGR?

Work-related psychosocial risk factors fall within the scope of Occupational Risk Management and must be taken into account in the management process and in the applicable documents. :contentReference[oaicite:15]{index=15}

Does the company need to create a specific document on psychosocial risks?

The focus of NR-1 is not simply to create a standalone document, but to properly manage occupational risks, including work-related psychosocial factors.

Is there a specific checklist for assessing psychosocial risks?

According to the MTE, there is currently no single operational protocol or exclusive national checklist for this type of inspection. The analysis takes into account the applicable requirements, the methodology used, and the actual working conditions. :contentReference[oaicite:16]{index=16}

Can inspections for NR-1 begin now?

Yes. The new provisions have been in effect since May 26, 2026. Regarding the new provisions related to psychosocial risks, the MTE announced the implementation of the “double visit” criterion, which will initially serve as a guideline during the 90 days following the provisions’ entry into force, in accordance with official guidelines. :contentReference[oaicite:17]{index=17}

Who is responsible for addressing psychosocial risks?

Management should be integrated into the organization’s Occupational Safety and Health structure. Human Resources, leadership, managers, and other departments can contribute information and measures in accordance with their respective responsibilities.

The update to the No. 1 in 2026 It underscores a significant shift in the way companies need to view occupational risk management.

Workplace safety should not be limited to physical, chemical, or accident-related risks.

Work organization also needs to be taken into account.

For companies, the challenge now is to turn this requirement into a structured routine that includes:

Identification → Assessment → Prevention → Control → Evidence → Monitoring → Improvement

The main point is not to create yet another document.

It means demonstrating that the organization understands its risks, has preventive measures in place, and continuously monitors their effectiveness.

Mature companies don't wait for an audit to discover their shortcomings.

They use risk management to identify problems early on, prioritize actions, and strengthen their operations.

NR-1 can be viewed simply as a new regulatory requirement.

Or it can be used as an opportunity to enhance the maturity of the company's risk management.

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