What happened?

OSHA’s annual cycle is now open for 2025 injury/illness data. Covered employers must post OSHA Form 300A from February 1 through April 30, 2026, and required establishments must electronically submit 2025 data by March 2, 2026, via OSHA’s Injury Tracking Application (ITA).

• In certain designated high‑hazard industries (including manufacturing), establishments with 100 or more employees must also submit OSHA Forms 300 and 301 case-level data in addition to Form 300A.

• Size and industry partial exemptions remain in place, and all employers must continue to report severe incidents (8/24‑hour rule).

What is OSHA Form 300A? It is the Annual Summary of work‑related injuries and illnesses from the OSHA 300 Log that must be certified by a company executive and posted February 1 – April 30 of the following year.

Overview

Covered employers must finalize their 2025 OSHA logs, obtain executive certification, and post the Form 300A where employee notices are customarily displayed from February 1 to April 30, 2026.

Separately, establishments meeting OSHA’s electronic reporting thresholds must submit 2025 data (300A, and for some, 300/301) through the ITA by March 2, 2026.

Note: Employers operating in states that have their own OSHA State Plan should confirm whether additional or different electronic reporting requirements apply.

Why this matters: OSHA uses electronically submitted data to identify hazards and target outreach/enforcement, and it publishes portions of the information, increasing transparency for workers, applicants, and the public. Non‑submission or inaccurate data can elevate compliance risk.

Action Steps for Compliance

• Close out 2025 records: Review the OSHA 300 Log, correct deficiencies, create the 300A Annual Summary, and secure company executive certification.

• Posting: Post the 300A at each establishment February 1 – April 30, 2026 in a conspicuous location.

• Electronic Reporting Obligations: Determine electronic reporting obligations using OSHA’s ITA Coverage Application (establishment‑level, not companywide).

• Submission Date: Submit by March 2, 2026via OSHA’s Injury Tracking Application (ITA) using any of these methods: web form, CSV upload, or API.

• Submission Requirements:
  
  • Form 300A (Summary)
    • Establishments with 250 or more employees, and
    • Establishments with 20–249 employees in designated industries.
      
  • Forms 300 & 301 (case level data) – in addition to 300A
    • Establishments with 100 or more employees in designated high hazard industries.

• Submission Requirements:

• Form 300A (Summary)

• Establishments with 250 or more employees, and
  • Establishments with 20–249 employees in designated industries.

• Forms 300 & 301 (case‑level data) – in addition to 300A

• Establishments with 100 or more employees in designated high‑hazard industries.

• Apply exemptions correctly: Employers with 10 or fewer employees at all times in 2025 or establishments in partially exempt (low‑hazard) industries are generally exempt from routine recordkeeping (severe‑incident reporting still applies).

• Retain records for five years and update the OSHA 300 Log as needed during the retention period.

• Report severe incidents: Fatality within 8 hours; in‑patient hospitalization, amputation, or loss of an eye within 24 hours (by phone or online)

Additional Information

What is the ITA? OSHA’s Injury Tracking Application is the secure portal where covered establishments electronically submit 300A (and, where required, 300/301) data; the 2025 collection opened January 2, 2026, and is due March 2, 2026.

Who is partially exempt? Companies with 10 or fewer employees for all of 2025 and low‑hazard NAICS establishments listed in Appendix A are generally exempt from routine recordkeeping.

Key Risks for Employers

• Missing the posting window (February 1–April 30) or lack of executive certification on the 300A can result in citations.

• Failure to file electronically by March 2, 2026 (where required) exposes establishments to enforcement and public scrutiny of safety records once data is published.

• Incorrect coverage determinations (e.g., counting company‑wide headcount instead of establishment‑level thresholds for electronic submission, or misapplying size/industry exemptions) can lead to under‑ or over‑reporting.

• Not reporting severe incidents within 8 to 24 hours (fatality/hospitalization/amputation/eye loss) is a separate violation from recordkeeping.

For additional details:

• OSHA Injury & Illness Recordkeeping Forms – 300, 300A, 301
• OSHA Form 300 Partially Exempt Industries
• OSHA Injury Tracking Application (ITA) Information
• OSHA Injury Tracking Application (ITA) Log in
• OSHA ITA Coverage Application
• OSHA State Plan
• Reminder Federal: OSHA Form 300 Posting Begins on February 1, 2025, and the Electronic Submission Required by March 2, 2025 (VensureHR)

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