{"id":7312,"date":"2026-09-11T09:00:00","date_gmt":"2026-09-11T01:00:00","guid":{"rendered":"https:\/\/nowserving.ph\/blog\/?p=7312"},"modified":"2026-10-19T13:35:35","modified_gmt":"2026-10-19T05:35:35","slug":"dole-annual-medical-exam-employer-requirement","status":"publish","type":"post","link":"https:\/\/nowserving.ph\/blog\/dole-annual-medical-exam-employer-requirement\/","title":{"rendered":"Is Your Company Required to Provide an Annual Physical Exam? DOLE Rules Explained"},"content":{"rendered":"

An annual physical exam is exactly what it sounds like: a yearly medical checkup your employer arranges for you. DOLE, the Department of Labor and Employment, is the government body that sets the rule behind it, including how often it has to happen. This guide breaks down that rule so you can tell whether your company is actually required to provide one, and what to do if it isn’t.<\/span><\/p>\n

This guide explains what the rules say as of August 2026. It is general information, not legal advice. For your own situation, talk to a labor lawyer or the DOLE regional office covering your workplace.<\/em><\/p>\n

Why is the annual physical exam (APE) a requirement?<\/b><\/h2>\n

OSHS or the Occupational Safety and Health Standards is a DOLE standard first issued in 1978 and amended since. Rule 1967 is the part that covers workplace medical examinations.<\/span><\/p>\n

Four occasions trigger the exam under Rule 1967(1): “All workers, irrespective of age and sex, shall undergo physical examination: a. before entering employment for the first time; b. periodically, or at such intervals as may be necessary on account of the conditions or risks involved in the work; c. when transferred or separated from employment; and d. when injured or ill.”<\/span><\/p>\n

The terms attached in Rule 1967(2): “All examinations shall: a. be complete and thorough; b. be rendered free of charge to the workers; and c. include X-ray or special laboratory examinations when necessary due to the peculiar nature of the employment.”<\/span><\/p>\n

A final constraint comes from Rule 1967.03(6): “Shall have an interval of not longer than one year between two (2) consecutive periodic physical examinations.”<\/span><\/p>\n

In short, every worker gets a periodic examination, the worker doesn’t pay for it, and no more than twelve months may pass between one and the next.<\/span><\/p>\n

Learn what is APE and why employees need it<\/i><\/b><\/a><\/span><\/h4>\n

\"medical<\/p>\n

Where the word “annual” comes from<\/b><\/h3>\n

The sub-rule holding that twelve-month cap is headed “Periodic Annual Medical Examinations”. That heading is the source of the popular shorthand, and it’s a reasonable one.<\/span><\/p>\n

Who the rule covers<\/b><\/h3>\n

Rule 1961.01(1) is broad: “This Rule shall apply to all establishments whether for profit or not, including the Government and any of its political subdivisions and government-owned or controlled corporations.”<\/span><\/p>\n

What keeps a 1978 standard alive in 2026<\/b><\/h3>\n

RA 11058, the 2018 OSH law, does the statutory work. Section 3(j) defines “OSH standards” as the Occupational Safety and Health Standards issued by the Secretary of Labor under Articles 168 and 171 of the Labor Code, and Section 4(a)(5) makes it the employer’s duty to “Comply with OSH standards including training medical examination and where necessary, provision of protective and safety devices”.<\/span><\/p>\n

The current implementing rules repeat the instruction. DO 252-25 Sec. 4(a)(7) requires employers to “Comply with OSHS requirements, including training, medical examinations, and the provision and use of protective and safety devices such as machine guards and PPE”.<\/span><\/p>\n

At Section 20, the older DO 198-18 was blunter about it: “All employers shall comply with other occupational safety and health standards as provided for in the 1978 DOLE Occupational Safety and Health Standards, as amended.”<\/span><\/p>\n

What RA 11058 and DO 198-18 actually say<\/b><\/h2>\n

Most of the confusion on this topic is a citation problem rather than a substance problem. The duty is real, but the instruments people attach it to don’t contain it.<\/span><\/p>\n

Medical surveillance and an annual physical are different things<\/b><\/h3>\n

An ongoing program element aimed at occupational and work-related disease, medical surveillance is not the same as a periodic physical examination, which is a scheduled event with a cap on the interval between events.<\/span><\/p>\n

\"medical<\/p>\n

A company can run one without the other. So if a compliance checklist has ticked the medical surveillance box, that box says nothing about whether anyone has had a physical examination in the last twelve months.<\/span><\/p>\n

DO 198-18 stopped being the live rules in May 2025<\/b><\/h3>\n

Effective 16 May 2025, DO 252-25 superseded DO 198-18. Any article, HR memo or compliance checklist still describing DO 198-18 as the operative implementing rules is out of date, including its penalty amounts.<\/span><\/p>\n

That’s a useful dating test. If a page cites DO 198-18 as current law, it was written before May 2025 or copied from something that was.<\/span><\/p>\n

Five ways this is narrower than it sounds<\/b><\/h2>\n

Each of these matters to a real employer, and none of them cancels the duty.<\/span><\/p>\n

1. The duty is regulatory, not statutory<\/b><\/h3>\n

Rule 1967 is a DOLE standard issued under Labor Code Art. 168, so “the law requires it” is defensible while “RA 11058 requires it” isn’t.<\/span><\/p>\n

That difference matters in practice. A standard can be amended by DOLE without an act of Congress, so the text you’re relying on can change faster than a statute would.<\/span><\/p>\n

2. The instruments most people cite were replaced<\/b><\/h3>\n

Covered above. DO 198-18 is superseded. <\/span><\/p>\n

3. Transportation and mining sit outside the standard<\/b><\/h3>\n

OSHS Rules 1003.03 and 1003.04 exclude land, sea and air transportation establishments, except their garages, dry docks, hangars, maintenance and repair shops. Mining activities are excluded too.<\/span><\/p>\n

So a shipping company’s vessels sit outside the standard while its repair shop sits inside it. Other rules may cover those activities, so the carve-out doesn’t mean nothing applies to them.<\/span><\/p>\n

4. The Labor Code route only reaches employers above 200 workers<\/b><\/h3>\n

Philippine law states this most cleanly in the Omnibus Rules Implementing the Labor Code, Book IV Rule I Sec. 9: “The physician engaged by an employer pursuant to this Rule shall … (b) Conduct free of charge annual physical examination of the workers;”<\/span><\/p>\n

Read the subject. The duty attaches to a physician engaged under that Rule, and Sec. 4(c) and (d) require a physician only above 200 workers, or above 300 in a hazardous workplace. A 30-person office has no such physician, so it has no Sec. 9 duty at all.<\/span><\/p>\n

Only the Rule 1967 route reaches small employers, because it speaks to “all workers” without conditioning on staffing.<\/span><\/p>\n

5. Staffing ratios are a separate question<\/b><\/h3>\n

RA 11058 Sec. 15 scales first-aiders, nurses, dentists and physicians by headcount and risk classification. That governs who must be on site.<\/span><\/p>\n

It doesn’t decide whether the examination is owed. Those two questions get conflated constantly, and the answer to one tells you nothing about the other.<\/span><\/p>\n

Learn the rules about getting APE as an employee<\/i><\/b><\/a><\/span><\/h4>\n

“Annual” is a maximum interval, not a date you can demand<\/b><\/h2>\n

What the frequency is tied to<\/b><\/h3>\n

The base rule is risk, not the calendar. Rule 1967(1)(b) says examinations happen “periodically, or at such intervals as may be necessary on account of the conditions or risks involved in the work”, and Rule 1967.03(4) adds that they “Shall be as frequent as the nature of employment may warrant taking into consideration the special hazards involved and their relative importance.”<\/span><\/p>\n

What that means in practice<\/b><\/h3>\n

“At least once a year” is a fair paraphrase of the rule. “I’m entitled to an annual physical exam on a specific date” isn’t supported by the text.<\/span><\/p>\n

If your last examination was in March and this year’s lands in November, that’s still inside the rule. Push it to the following April instead, and it isn’t.<\/span><\/p>\n

Who pays, and the parts that are only conditionally free<\/b><\/h2>\n

The unconditional sentence<\/b><\/h3>\n

Rule 1967(2)(b) says all examinations shall “be rendered free of charge to the workers”. On its face there’s no condition attached, and it covers all four occasions listed in Rule 1967(1).<\/span><\/p>\n

The components that come with a condition<\/b><\/h3>\n\n\n\n\n\n\n\n\n\n
\n

Component<\/b><\/p>\n<\/td>\n

\n

Free to the worker?<\/b><\/p>\n<\/td>\n

\n

Rule<\/b><\/p>\n<\/td>\n

\n

The condition<\/b><\/p>\n<\/td>\n<\/tr>\n

\n

The periodic physical examination<\/span><\/p>\n<\/td>\n

\n

Yes<\/span><\/p>\n<\/td>\n

\n

1967(2)(b)<\/span><\/p>\n<\/td>\n

\n

None on the face of the text<\/span><\/p>\n<\/td>\n<\/tr>\n

\n

Special examinations<\/span><\/p>\n<\/td>\n

\n

For exposed workers<\/span><\/p>\n<\/td>\n

\n

1967.03(2)<\/span><\/p>\n<\/td>\n

\n

Only where workers are exposed to occupational health hazards<\/span><\/p>\n<\/td>\n<\/tr>\n

\n

Chest x-ray in the periodic exam<\/span><\/p>\n<\/td>\n

\n

Where feasible<\/span><\/p>\n<\/td>\n

\n

1967.03(3)<\/span><\/p>\n<\/td>\n

\n

Free “whenever feasible”, “at least once a year”<\/span><\/p>\n<\/td>\n<\/tr>\n

\n

Biochemical monitoring<\/span><\/p>\n<\/td>\n

\n

For exposed workers<\/span><\/p>\n<\/td>\n

\n

1967.03(5)<\/span><\/p>\n<\/td>\n

\n

Only for workers exposed to toxic substances<\/span><\/p>\n<\/td>\n<\/tr>\n

\n

Pre-employment chest x-ray<\/span><\/p>\n<\/td>\n

\n

Often not<\/span><\/p>\n<\/td>\n

\n

1967.01(2)(b)(iii)<\/span><\/p>\n<\/td>\n

\n

“in all other instances, the applicant shall pay the cost of the examination”<\/span><\/p>\n<\/td>\n<\/tr>\n

\n

Personal protective equipment<\/span><\/p>\n<\/td>\n

\n

Yes<\/span><\/p>\n<\/td>\n

\n

RA 11058 Sec. 8<\/span><\/p>\n<\/td>\n

\n

The only express free-of-charge worker right in RA 11058<\/span><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Pre-employment is treated differently on purpose<\/b><\/h3>\n

Rule 1967(2)(b) runs to “the workers”, and the pre-employment paragraph calls the person an “applicant”. That distinction continues in Rule 1967.01(2)(b)(iii), which says outright that “in all other instances, the applicant shall pay the cost of the examination.”<\/span><\/p>\n

\"person<\/p>\n

So the blanket claim that an employer must always shoulder the pre-employment medical isn’t supported by the OSHS text. We went through that separately in the pre-employment medical exam guide.<\/span><\/p>\n

How to check a legal citation yourself<\/b><\/h2>\n

Why this matters more here than usual<\/b><\/h3>\n

One claim says “Section 12 of DO 198-18 explicitly outlines employers’ duties, including the provision of free annual physical examinations to all employees.” Section 12 is about the contents of the OSH program, and its medical clause, Sec. 12(b)(2), is the medical surveillance sentence quoted above.<\/span><\/p>\n

Another cites “DO 198-18 Sec. 11(j)”. Section 11 has only subsections (a) through (d).<\/span><\/p>\n

A third cites “RA 11058 Sec. 32” for penalties. Section 32 is the clause directing the issuance of implementing rules. Penalties are in Section 28.<\/span><\/p>\n

We’re not naming the sites, because the pattern is the useful part, not the target.<\/span><\/p>\n

The check, in three steps<\/b><\/h3>\n

Open the instrument itself rather than a summary of it. Then find the section number and read the subsection letter; if the letter doesn’t exist, the citation is wrong and nothing else about the claim needs checking.<\/span><\/p>\n

Last, search the document for the exact phrase being attributed to it. A real requirement survives a text search; a fabricated one doesn’t.<\/span><\/p>\n

The rule texts quoted here were read from the ILO’s NATLEX database, which reprints DOLE-BWC and OSHC texts, and from lawphil.net.<\/span><\/p>\n

What happens if an employer doesn’t run one<\/b><\/h2>\n

The statutory fine<\/b><\/h3>\n

RA 11058 Sec. 28(a) allows an administrative fine “not exceeding One hundred thousand pesos (P100,000.00) per day until the violation is corrected”, and the maximum is reserved for violations that expose workers to the risk of death, serious injury or serious illness.<\/span><\/p>\n

The old schedule never named medical exams<\/b><\/h3>\n

DO 198-18 Sec. 29 carried a schedule running from PHP 20,000 to PHP 50,000 per day. No line item was named “medical examinations.” The nearest fit was “Compliance to other OSH standards P40,000.00”.<\/span><\/p>\n

What HR should actually do about it<\/b><\/h2>\n

Treat it as an operations cost, because the law calls it one<\/b><\/h3>\n

RA 11058 Sec. 20: “The total cost of implementing a duly approved safety and health program shall be an integral part of the operations cost.”<\/span><\/p>\n

That’s a budgeting line rather than a discretionary perk, and it’s a useful sentence to have on hand when the request goes to finance.<\/span><\/p>\n

Keep the record per worker, not per company<\/b><\/h3>\n

Practical rather than legal: the thing that gets breached is the gap between two examinations for one person, so a company-wide “we ran a medical in 2025” doesn’t answer the question for a worker hired in March 2026.<\/span><\/p>\n

If you’re the person who has to make this happen for a workforce, the logistics are usually the harder half; NowExpress offers a standard annual physical exam package<\/a> you can book.<\/span><\/p>\n

The cost is usually smaller than the debate about it<\/b><\/h3>\n

Employers in the Philippines typically budget for the Basic 5: a physical examination by a doctor, a complete blood count, a routine urinalysis, a fecalysis, and a chest x-ray. We broke down what each test looks for in the annual physical exam guide.<\/span><\/p>\n

Prices for the same five tests vary a lot by where you go, and so does the facility you send people to, which our guide to finding a diagnostic center covers. Kaiser Medical Center publishes its Basic 5 at PHP 850 per person. Makati Medical Center’s outpatient list, effective 1 March 2026, puts the same five at PHP 4,200. Both figures were checked on 10 August 2026 on the providers’ own pages.<\/span><\/p>\n

For 200 people, that’s PHP 170,000 a year at the clinic-chain price and PHP 840,000 at the hospital price. Corporate rates are negotiated rather than published, so treat both as reference points. There’s more on structuring it as a program in our guide to the annual physical exam for employees.<\/span><\/p>\n

Read this related article to know the APE packages and costs<\/i><\/b><\/a><\/span><\/h4>\n

What an employee can do if there’s no annual medical<\/b><\/h2>\n

Ask what the schedule is first<\/b><\/h3>\n

Many companies run examinations by hire date rather than all at once, so “we haven’t had one” sometimes just means yours is in October.<\/span><\/p>\n

If there genuinely isn’t a schedule<\/b><\/h3>\n

Ask for the periodic physical examination under OSHS Rule 1967, free of charge. Naming that rule is more useful than naming a law that doesn’t contain the requirement, and an HR team checking the citation will find it.<\/span><\/p>\n

Labor standards concerns go to the DOLE regional office covering your workplace. This article is general information rather than legal advice, so unresolved cases should go to a labor lawyer or to that regional office.<\/span><\/p>\n

If you were charged for one<\/b><\/h3>\n

Rule 1967(2)(b) says examinations shall “be rendered free of charge to the workers”, so if you’re already employed and were charged for a periodic examination, raise it with HR first, then with your DOLE regional office.<\/span><\/p>\n

The pre-employment case is genuinely different, since Rule 1967.01(2)(b)(iii) expressly contemplates an applicant paying.<\/span><\/p>\n

Before you rely on this<\/b><\/h2>\n

Parts of the newest implementing rules, DOLE Department Order 252-25, could not be read in full, so check the current text with DOLE before relying on the details.<\/span><\/p>\n

Frequently asked questions<\/b><\/h2>\n

Is an annual physical exam required by law in the Philippines?<\/b><\/h3>\n

Yes, in substance. The DOLE Occupational Safety and Health Standards requires all workers to undergo physical examination “periodically, or at such intervals as may be necessary on account of the conditions or risks involved in the work” (Rule 1967(1)(b)), and Rule 1967.03(6) caps the gap at “not longer than one year between two (2) consecutive periodic physical examinations”. Transportation establishments and mining activities sit outside the standard.<\/span><\/p>\n

Does RA 11058 require free annual physical examinations?<\/b><\/h3>\n

No. The free-of-charge provision in RA 11058, Section 8, covers personal protective equipment only, and the phrase “annual physical examination” doesn’t appear in the law. What RA 11058 does is define OSH standards as the OSHS (Sec. 3(j)) and require employers to “Comply with OSH standards including training medical examination” (Sec. 4(a)(5)).<\/span><\/p>\n

Does Section 12 of DO 198-18 require free annual physical exams?<\/b><\/h3>\n

No. Section 12(b)(2) requires “Medical surveillance for early detection and management of occupational and work-related diseases”, which is a different obligation. DO 198-18 was also superseded by DOLE Department Order 252-25 on 16 May 2025, so any page citing it as live law is out of date.<\/span><\/p>\n

Does my employer have to pay for it?<\/b><\/h3>\n

For a periodic examination of an existing worker, yes. OSHS Rule 1967(2)(b) says all examinations shall “be rendered free of charge to the workers”. Three components are conditional: special examinations for hazard-exposed workers (Rule 1967.03(2)), the chest x-ray “whenever feasible” (Rule 1967.03(3)), and biochemical monitoring for workers exposed to toxic substances (Rule 1967.03(5)).<\/span><\/p>\n

Does the rule apply to a company with only 30 employees?<\/b><\/h3>\n

Yes. OSHS Rule 1967 speaks to “all workers” and sets no headcount threshold. The separate Labor Code route works differently: Omnibus Rules Book IV Rule I Sec. 9(b) requires “free of charge annual physical examination of the workers”, but it binds only a physician engaged under that Rule, and a physician is required only above 200 workers.<\/span><\/p>\n

Which employers are exempt?<\/b><\/h3>\n

OSHS Rules 1003.03 and 1003.04 exclude land, sea and air transportation establishments, except their garages, dry docks, hangars, maintenance and repair shops. Mining activities are excluded as well.<\/span><\/p>\n

What is the penalty for not providing one?<\/b><\/h3>\n

RA 11058 Sec. 28(a) allows an administrative fine “not exceeding One hundred thousand pesos (P100,000.00) per day until the violation is corrected”, with the maximum reserved for violations that expose workers to the risk of death, serious injury or serious illness. The current penalty provision is DO 252-25 Sec. 42, whose text we could not read, so no amount here is cited to it.<\/span><\/p>\n

What can I do if my employer doesn’t run one?<\/b><\/h3>\n

Ask what the schedule is first, since many companies run it by hire date rather than all at once. If there’s no schedule at all, ask for the periodic physical examination under OSHS Rule 1967, free of charge, and name the rule rather than a law that doesn’t contain it. Labor standards concerns go to the DOLE regional office covering your workplace.<\/span><\/p>\n

Is the pre-employment medical exam free as well?<\/b><\/h3>\n

Not necessarily. Rule 1967(2)(b) runs to “the workers”, while the pre-employment paragraph calls the person an “applicant”, and Rule 1967.01(2)(b)(iii) says “in all other instances, the applicant shall pay the cost of the examination”.<\/span><\/p>\n

Schedule Your Annual Physical Examination on NowExpress!<\/b><\/a><\/p>\n\n\n