Foreign Companies Operating in Brazil: Is Your Business Prepared for NR-1 & the New Workplace Psychosocial Risk Rules?

By Paula Thevenet

The update to Regulatory Standard No. 1 expands companies’ duty to manage occupational risks and places mental health, work organization, and corporate culture at the center of labor inspection in Brazil.

Regulatory Standard No. 1, known in Brazil as NR-1, establishes the general provisions on occupational health and safety. The updated rule is already in force and imposes a significant change in how companies must manage occupational risks.

More than a technical update, the new NR-1 represents a concrete shift in how public authorities will inspect organizations and how companies must structure their internal processes to ensure legal compliance.

Among the main requirements already in force is the need to review and adapt the Occupational Risk Management system, known as GRO, and the Risk Management Program, known as PGR. These instruments now require a broader and more strategic approach from employers.

The main innovation introduced by the update is the express inclusion of psychosocial risks in occupational risk management. Until now, factors related to mental health and work organization were usually analyzed indirectly, especially from an ergonomic perspective. They now formally form part of companies’ legal obligations.

In practice, this means that issues such as abusive targets, excessive working hours, disproportionate pressure, moral or sexual harassment, interpersonal conflicts, lack of autonomy, work overload, and management failures must be identified, assessed, controlled, and monitored by companies.

This change in perspective is highly relevant: the focus is no longer exclusively on the worker, but also on the business activity itself and on how work is organized. As a result, management decisions, leadership models, performance criteria, and operational structures may also be analyzed from an occupational health standpoint.

What must companies do now?

Compliance with the new NR-1 requires an active approach. It is not enough to acknowledge that risk factors exist. Companies must formally document them, maintain an updated risk inventory, analyze the areas or roles most exposed, and prepare a specific action plan.

In addition, the company must be able to demonstrate that it has adopted concrete measures to mitigate risk factors, such as:

• reviewing targets and deadlines;
• reorganizing working hours and task distribution;
• adjusting management and leadership processes;
• implementing or strengthening harassment prevention policies;
• creating effective internal listening and reporting channels;
• training managers and leadership teams.

It is important to highlight that there is no standardized solution. Each organization must build its own strategy according to its size, business sector, internal structure, and specific risks.

Another essential point is that compliance does not end with the preparation of a document. This is a continuous process that requires monitoring, periodic reassessment, and updates whenever relevant changes occur in the company’s business dynamics.

It is also important to clarify that the new NR-1 does not require companies to hire psychologists or create isolated wellness programs. Corporate benefits may be positive, but they do not replace the main obligation: reviewing work practices that may cause distress or occupational illness.

How will labor inspection work?

With the entry into force of the updated standard, labor inspection in Brazil expands its scope of analysis. Labor inspectors may verify not only physical aspects of the workplace, but also how work is organized and performed within the company.

This includes the analysis of documents such as the PGR, risk inventories, action plans, and internal records, as well as the assessment of factors such as working hours, target policies, the relationship between leaders and teams, reporting channels, and measures adopted to prevent occupational illness.

Although the beginning of the rule’s effectiveness was accompanied by an initial guidance period, with priority given to educational measures and notifications for compliance, this does not mean that there is no risk.

In serious situations or in cases of clear non-compliance, administrative measures and fines may be imposed.

A company may be held liable, for example, if it:

• fails to identify existing psychosocial risks;
• identifies the risks but fails to adopt concrete measures;
• implements insufficient or merely formal actions;
• fails to monitor and reassess risks over time.

Even though companies may present a defense in administrative proceedings, the financial and reputational cost of an inspection penalty may be significantly higher than the preventive investment required for compliance.

Conclusion

The update to NR-1 sends a clear message to foreign companies operating in Brazil: people management, organizational culture, and occupational health have definitively become part of the country’s labor compliance agenda.

Ignoring this change increases exposure to labor liabilities, administrative penalties, and reputational damage. On the other hand, companies that treat compliance as a strategic matter strengthen governance, reduce risks, and build more sustainable and productive work environments.

More than a legal obligation, this is an opportunity to turn prevention into a competitive advantage. In this context, specialized legal assistance may be decisive to ensure that your company is protected, compliant, and prepared for the new regulatory challenges of doing business in Brazil.

References

BRAZIL. Constitution of the Federative Republic of Brazil of 1988. Brasília, DF: Presidency of the Republic, 1988. Available at: https://www.planalto.gov.br/ccivil_03/constituicao/constituicao.htm. Accessed on: June 30, 2026.

BRAZIL. Decree-Law No. 5,452, of May 1, 1943. Approves the Consolidation of Labor Laws. Official Gazette of the Union, Brasília, DF, August 9, 1943. Available at: https://www.planalto.gov.br/ccivil_03/decreto-lei/del5452.htm. Accessed on: June 30, 2026.

BRAZIL. Federal Law No. 6,514, of December 22, 1977. Amends Chapter V of Title II of the Consolidation of Labor Laws, concerning occupational safety and medicine. Official Gazette of the Union, Brasília, DF, December 23, 1977. Available at: https://www.planalto.gov.br/ccivil_03/leis/l6514.htm. Accessed on: June 30, 2026.

BRAZIL. Ministry of Labor. Ordinance No. 3,214, of June 8, 1978. Approves the Regulatory Standards of Chapter V, Title II, of the Consolidation of Labor Laws, concerning occupational safety and medicine. Official Gazette of the Union, Brasília, DF, July 6, 1978.

BRAZIL. Ministry of Labor and Employment. Regulatory Standard No. 1 — General Provisions and Occupational Risk Management. Brasília, DF: Ministry of Labor and Employment, 2026. Available at: https://www.gov.br/trabalho-e-emprego. Accessed on: June 30, 2026.

BRAZIL. Ministry of Labor and Employment. MTE Ordinance No. 1,419, of August 27, 2024. Amends Regulatory Standard No. 1 — General Provisions and Occupational Risk Management. Official Gazette of the Union, Brasília, DF, August 28, 2024.

BRAZIL. Ministry of Labor and Employment. MTE Ordinance No. 765, of May 15, 2025. Amends the effective date of the provisions of MTE Ordinance No. 1,419, of August 27, 2024. Official Gazette of the Union, Brasília, DF, May 16, 2025.