Europe is in the middle of another intense heatwave. Temperatures have exceeded 40°C in several cities, and forecasts suggest the current weather system will persist well into July. Extreme heat is a health risk for everyone, and for workers it also carries a specific legal dimension that employers cannot ignore.
The numbers are significant. According to a report published on 25 June 2026 by EFFAT, EPSU, and EFBWW, around 130 million workers across the EU are exposed to workplace heat stress every year, with an estimated 277,000 injuries and 230 deaths linked to it annually. EU-OSHA’s OSH Pulse 2025 survey found that around one in five workers across the EU have faced extreme heat on the job in the last twelve months, whether indoors or outdoors.
What the EU framework directive requires
The legal foundation for heat stress management in European workplaces is the Framework Directive 89/391/EEC. Article 5 establishes that employers must ensure the safety and health of workers in every aspect related to work, including the obligation to assess all risks and put in place the required preventive and protective measures.
Heat is a covered risk under this framework. Existing obligations are enforceable under national law, and employers cannot argue that extreme temperatures fall outside their duty of care. EU Member States require employers to carry out workplace risk assessments and set preventive measures following the hierarchy of control, giving priority to technical and organisational solutions before resorting to personal protective equipment.
ISO 45001 reinforces this approach: heat stress must be identified, assessed, and controlled within the broader occupational health and safety management system, with documented evidence of the measures adopted.
Where EU law is still evolving
The general duty of care is clear. What is less clear is how to measure heat exposure, when to intervene, and what specific protections workers are entitled to. Two heat-related topics are not addressed at all in EU law: the use of scientifically validated heat exposure indicators and acclimatisation to heat. Two further topics are only partially addressed: hydration strategies, and rest breaks or modified work schedules.
The result is significant variation in how heat risk is regulated across member states. On 25 June 2026, EFFAT, EPSU, and EFBWW unveiled a Model Directive publicly, calling on the European Commission to adopt it as the basis for binding legislation on heat at work as part of the upcoming Quality Jobs Act. Until binding rules are in place, compliance depends on how employers interpret general obligations, which creates uncertainty across sectors and borders.
What employers must do now
The existing framework already creates enforceable obligations regardless of whether a dedicated directive is adopted. The absence of specific rules does not eliminate employer obligations under the general duty of care.
Practical steps that fall within current legal obligations include scheduling physically demanding tasks during cooler hours, providing unrestricted access to water and shaded rest areas, supplying appropriate PPE for thermal conditions, and training workers to recognise the early signs of heat exhaustion and heat stroke.
EU-OSHA’s guidance document “Heat at work — Guidance for workplaces”, published in 2023 and available in all EU languages, provides a structured framework for implementing these measures. It covers exposure assessment, prevention hierarchies, and emergency response protocols.
Documenting high-risk work: the role of Permit to Work
Managing heat risk in a structured way also means documenting authorisations before high-risk activities begin. This is the underlying principle of the Permit to Work system: a formal verification of safety conditions prior to the start of an activity, with full traceability of who authorises, who executes, and which protective measures are in place.
4HSE is introducing a PTW module that will include specific forms for high-risk work categories: hot work, confined spaces, electrical work, and work at height. Each permit will be verifiable on-site via QR code scan, without needing desktop access to the platform. All documentation remains stored and traceable, available for inspection at any time.