Workplace First Aid Requirements: What Every UK Employer Must Provide

What follows sets out what the law requires, what HSE’s guidance adds on top, and what is simply good practice — kept separate, because most of the confusion about workplace first aid comes from blending the three. It corrects the “one first aider per 50 employees” figure that circulates online, explains the 2024 changes to HSE’s guidance that most guides have not caught up with, and gives you a decision table you can act on.

Last reviewed: 20 September 2026 against HSE’s guidance L74 (2024 amendments), GEIS3 (rev2, 2024) and HSE’s first-aid web pages (updated March 2025).

What does the law actually require?

Regulation 3 of the Health and Safety (First-Aid) Regulations 1981 requires an employer to provide, or ensure there are provided, “such equipment and facilities as are adequate and appropriate in the circumstances for enabling first-aid to be rendered to his employees if they are injured or become ill at work” — and to provide adequate and appropriate numbers of “suitable persons” to render it. Regulation 4 requires you to tell your employees what those arrangements are. Regulation 5 requires the self-employed to provide equipment for themselves.

That is the entire statutory duty. It does not name a course, a number of first aiders, a kit list or a form. Everything more specific than that comes from HSE’s guidance, chiefly the L74 guidance on the Regulations, which HSE says an inspector “may refer to” and which, if followed, means you “will normally be doing enough to comply with the law”. Guidance is not law, but ignoring it and doing less is a hard position to defend.

Who the Regulations cover

Every employer, of any size. HSE is explicit that the Regulations apply to workplaces with fewer than five employees. They cover your employees. They do not require you to provide first aid for members of the public, customers, pupils or contractors — but HSE strongly recommends that you include non-employees in your assessment and make provision for them, and that you check your liability insurance covers what your first aiders do for them (L74 paragraphs 28–29). For a shop, a school, a venue or a gym, that recommendation is effectively the standard you will be judged against.

The three things every employer must have

Whatever your needs assessment concludes, HSE’s employer guidance sets a floor that no workplace goes below:

1. A suitably stocked first aid kit. At least one per site, clearly identified by a white cross on a green background, checked and restocked regularly.
2. An appointed person to take charge of first aid arrangements — looking after the kit and facilities and calling the emergency services. This person needs no training, and someone in this role must be available whenever people are at work.
3. Information for all employees about the arrangements: where the kit is, who to call, what to do. A notice in a prominent place and a line in induction covers it.

A two-person office above a shop meets the law with those three things and nothing else, provided its assessment genuinely supports that. Most workplaces need more, and the assessment is how you find out.

What is a first aid needs assessment, and do I have to write it down?

A first aid needs assessment is the exercise of looking at your workplace and deciding what first aid provision is “adequate and appropriate” for it. HSE does not prescribe a format and does not require it to be written: L74 paragraph 9 says there is “no requirement for the assessment of first-aid needs to be formal or written down, although it may be useful for employers to retain a written record”. The reason to write it anyway is the same reason you write anything down in health and safety — it is how you show an inspector, an insurer or a tribunal that you decided rather than guessed.

L74 paragraph 10 lists the factors to consider. Each one changes what you provide:

Since the 2024 amendment to L74, HSE has added that the hazards and risks you assess “can be both physical; related to mental health” (paragraph 8). That does not make mental health first aid training mandatory — see below — but it does mean an assessment that ignores the mental health of the workforce is now visibly incomplete.

Review the assessment after any operating change: a new site, new machinery, a change of shift pattern, a rise in headcount, a serious incident. HSE recommends keeping a record of incidents first aiders attend, precisely so that the next assessment is built on evidence. For the step-by-step method, twelve worked examples from HSE’s own case studies and a template you can fill in, see our guide to the first aid needs assessment; for numbers specifically, see how many first aiders does my workplace need.

How many first aiders do I need?

The law sets no number, and HSE publishes no ratio. HSE’s employer page says: “There are no hard and fast rules on exact numbers, and you will need to take into account all the relevant circumstances of your particular workplace.” L74 paragraph 53 says the same in different words: “There are no standard rules on exact numbers.”

The one numeric threshold HSE does state in text is in L74 paragraph 52: “Where 25 or more people are employed, even in low-hazard environments, at least one such person should be provided” — “such person” meaning a trained first aider. Below 25 in a low-hazard workplace, an appointed person and a kit can be enough; above it, HSE expects a first aider even in an office. L74’s Appendix 3 offers a flowchart of suggested numbers, which HSE describes as “suggestions only” that the employer must weigh against “all relevant information”.

The figures you will see repeated elsewhere are not HSE’s:

The practical approach is to start from coverage rather than a ratio: for every hour someone is at work, on every floor or building where help would otherwise be slow, is a first aider (or, where the assessment allows it, an appointed person) available — including when the usual one is on holiday? If the answer is yes, your number is right for you. If it needs a ratio to justify it, it probably is not.

Appointed person or trained first aider?

These are different roles and the difference matters, because an appointed person is not a first aider and cannot stand in for one.

The absence rule catches a lot of small businesses. One trained first aider plus “the receptionist keeps an eye on things when she’s off” is not compliant if your assessment says a first aider is required: annual leave is planned, so it must be covered by another first aider. Two EFAW-trained staff is the usual, inexpensive answer.

Which course do my first aiders need?

HSE’s guidance is built around an optional four-layer framework: appointed person, Emergency First Aid at Work (EFAW), First Aid at Work (FAW), and additional training on top. You do not have to use it, but almost everyone does, because a certificate that says FAW or EFAW is understood by every inspector and insurer.

Which level you choose follows from the assessment: EFAW where the foreseeable need is to keep someone alive until an ambulance arrives; FAW where the injuries listed in its syllabus are realistically part of your risk profile, where you employ 25 or more, or where a first aider may be the only trained person for some time. The full comparison is in First Aid at Work: 1 day or 3 days?. Doctors registered with the GMC, nurses with the NMC and paramedics with the HCPC do not need a FAW or EFAW certificate provided their first aid knowledge and skills are current (L74 paragraph 70).

A decision table by workplace type

These are our recommendations from thirty years of assessments, sitting on top of HSE’s guidance — not rules. Your own assessment decides.

How long do certificates last, and what about refreshers?

Three years, for FAW, EFAW and any other first aid at work training (L74 paragraph 74). Employers “need to arrange retraining before certificates expire”. Once the date passes, the person “is no longer considered competent to act as a first-aider in the workplace” — which means your cover has a gap from that day, whatever the person still knows.

A lapsed FAW holder can take the two-day requalification “at any time after the expiry date”, but HSE adds that “it may be prudent to complete the three-day FAW course, especially where a considerable period – ie in excess of one month – has elapsed”. The employer decides which. EFAW is renewed by taking the one-day course again.

Annual refresher training is strongly recommended by HSE and is not mandatory (paragraph 75). It exists to stop skills decaying and to pick up changes in accepted practice — and there have been changes: the Resuscitation Council UK’s 2025 guidelines replaced the 2021 set. A refresher does not extend the certificate. Keep a register of first aiders with their certificate dates (paragraph 77): it is the simplest control there is, and the one most often missing. More on expiry, lapses and renewal in how long does a first aid certificate last.

Training time is work time. GEIS3 reminds employers that regulation 13 of the Management of Health and Safety at Work Regulations 1999 requires “adequate time” to be set aside “during the working day” for first aid training.

What first aid equipment and facilities are required?

First aid kits

There is no mandatory contents list. L74 Appendix 2 gives a suggested minimum for low-hazard work: a first aid guidance leaflet, 20 assorted sterile plasters, two sterile eye pads, two triangular bandages, six safety pins, two large and six medium sterile unmedicated dressings, and at least three pairs of disposable gloves. British Standard BS 8599 describes workplace kit sizes; HSE says to look for it when buying, and also says plainly that “by law, your kit doesn’t have to meet this standard”. What the kit must do is reflect your assessment: a construction site’s kit is not an office’s kit. Full detail, including how many kits and where to site them, is in workplace first aid kit requirements.

Tablets and medicines do not belong in it. First aid at work “does not include giving tablets or medicines to treat illness”, the only exception being aspirin for a suspected heart attack in line with accepted practice (paragraph 42). Paracetamol in the first aid box is a common, well-meant mistake. Check contents frequently, watch expiry dates on sterile items, and restock promptly after use. Mobile staff may need travelling kits, and anyone whose work takes them away from mains water for eye or wound irrigation needs sealed sterile water or saline.

Defibrillators

An AED is not a legal requirement. If your assessment leads you to provide one, the Provision and Use of Work Equipment Regulations 1998 apply: you must provide information and written instructions on its use, and fuller training “is likely to make the user more confident” (paragraph 44). AED use is already part of the FAW and EFAW syllabus. We supply defibrillators and cabinets alongside training.

First aid rooms

Required only where your assessment identifies the need — “usually… where there are higher hazards such as in chemical industries or on large construction sites, and in larger premises at a distance from medical services” (paragraph 48). If you do need one, L74 sets out what it should contain: a couch with working space around it, washable surfaces, running water, a means of communication, clinical waste disposal, and a notice giving the names and locations of first aiders.

Shifts, holidays, lone workers, multiple sites and homeworkers

These are where otherwise sound arrangements fail, because the assessment was done for a Tuesday morning at head office.

What changed in 2024?

The Regulations have not changed. HSE’s guidance has. The third edition of L74 was reissued in January 2024 with three amendments, and GEIS3 was revised at the same time:

• Mental health is part of the needs assessment. Hazards and risks “can be both physical; related to mental health”, and it “may also be helpful to have people trained to identify and understand mental ill health symptoms”. HSE stops short of requiring it; an FAW or EFAW holder “may already be able to provide initial support and reassurance”. Whether Mental Health First Aid training is worth having is a separate question — we answer it in is mental health first aid a legal requirement.
• “Catastrophic bleeding” became “life-threatening bleeding”, with new guidance. Where the assessment identifies it as a risk — L74 names agriculture, forestry, construction and remote locations, and suggests hospitality and events consider it for violent incidents — employers should ensure the training provider covers it on the FAW course, and consider haemostatic dressings, wound packing and tourniquets as additional equipment. We cover this in detail in life-threatening bleeding at work.
• Provider guidance was simplified. The substance is unchanged: you choose the provider, you check their competence.

HSE’s web guidance was refreshed in March 2025, adding a page on homeworkers and co-working spaces, and the Resuscitation Council UK published its 2025 guidelines. A “2026 compliance guide” that does not mention any of this was written from older material.

How do I choose a competent training provider?

Until 1 October 2013, HSE approved first aid training providers. It no longer does, and no provider is “HSE approved” today, whatever a website says. The duty to check competence moved to you, and HSE’s information sheet GEIS3, Selecting a first-aid training provider is the checklist for doing it. HSE “does not advocate, promote or support any particular option”.

Providers come by three routes: those offering nationally regulated qualifications through an awarding organisation regulated by Ofqual, SQA or Qualifications Wales; those operating under a voluntary accreditation scheme; and those operating independently. The Voluntary Aid Societies (St John Ambulance, British Red Cross, St Andrew’s First Aid) are a fourth option. None of these routes is required, and none removes your duty to check. GEIS3’s checks are:

• Trainers and assessors hold a current FAW certificate (or are a registered doctor, nurse or paramedic) and a recognised training or assessing qualification.
• Quality assurance: a documented plan with a designated, suitably qualified person who reviews trainers at least annually; course evaluation and complaints procedures; assessment records kept at least three years.
• Teaching current practice: in line with the Resuscitation Council UK’s current guidelines and the Voluntary Aid Societies’ manual.
• Syllabus and time: the FAW/EFAW content above, delivered in at least the minimum contact hours, in blocks of no less than two hours, within 10 weeks (FAW), 6 weeks (FAW requalification) or 3 weeks (EFAW).
• Class size: more than 12 candidates per trainer “may” raise concerns about individual assessment.
• Certificates that state the provider, the qualification, the candidate, three-year validity, that they were issued for the purposes of the 1981 Regulations, and that teaching followed currently accepted practice.

Blended learning (e-learning plus classroom) is acceptable with extra checks; HSE strongly recommends that the practical elements are assessed by direct observation. A wholly online “first aid at work” certificate does not meet that test. You are not required to write down the checks you made, but a record lets you show an inspector how you chose. A fuller walk-through is in how to choose a first aid training provider, and the difference between “regulated” and “accredited” — which is not what most people assume — is explained in what an accredited qualification actually means.

Records worth keeping

None of these is required by the 1981 Regulations. All of them are how compliance is demonstrated:

• The needs assessment, dated, with the reasoning — and a note of when it was last reviewed.
• A first aid incident book: date, time, place, who, what happened, what first aid was given, what happened next, and the first aider’s signature. Kept in line with data protection law. This is separate from the statutory accident book, though the two can be combined.
• A register of first aiders and appointed persons with certificate dates, so requalification is booked before expiry rather than after.
• The provider checks you made under GEIS3.
• Written agreements for shared sites.

Some injuries must also be reported to HSE under RIDDOR. That is a separate duty from first aid, and a first aid record is not a RIDDOR report.

Workplace first aid compliance checklist

1. Carry out (and write down) a first aid needs assessment covering all eleven L74 factors, including mental health and non-employees.
2. Provide at least one suitably stocked, clearly marked first aid kit per site, matched to the assessment; no tablets.
3. Name an appointed person available whenever people are at work — more than one if hours are long.
4. Where the assessment requires first aiders (higher hazards, 25 or more employed, public exposure, remote work), train enough of them to cover every shift, area and holiday.
5. Choose EFAW or FAW to match the foreseeable injuries; add hazard-specific training where L74 Appendix 4 applies.
6. Check the provider against GEIS3 and keep a note of the checks. Do not rely on “HSE approved”.
7. Give training in paid work time.
8. Diary requalification before the three-year expiry; consider annual refreshers.
9. Tell everyone: notices, induction, who the first aiders are and where the kit is.
10. Keep an incident book and a certificate register; review the assessment after any change or serious incident.

What this guide does not cover

It does not cover first aid for children in early years and school settings (the EYFS framework and Department for Education requirements apply), offshore, diving, mining, or vessels, which have their own regulations. It does not describe clinical first aid steps — those are taught, not read. It is written for Great Britain; Northern Ireland has equivalent but separate regulations.

First aid at work courses

The Training Co. has delivered workplace first aid training since 1996: Emergency First Aid at Work, First Aid at Work and FAW requalification, as open course places for individuals and as group courses at your premises for up to 12 people across Greater Manchester and the North West. We can help you with the needs assessment first, so that you buy the course your workplace needs rather than the one that sounds safest. If you are pricing it up, how much does first aid training cost explains how open and group courses are charged.

Deals

First Aid at Work Courses

Frequently asked questions

Is it a legal requirement to have a first aider at work?

Not in every workplace. The legal requirement is “adequate and appropriate” provision, decided by your needs assessment. In a low-hazard workplace with a small number of staff, an appointed person and a first aid kit can meet the law. HSE’s guidance says that where 25 or more people are employed, even in a low-hazard environment, at least one trained first aider should be provided, and higher-hazard work needs first aiders regardless of headcount.

Do the First-Aid Regulations apply to a business with only two or three employees?

Yes. HSE states that the Regulations apply to all workplaces, including those with fewer than five employees, and to the self-employed. The minimum provision is a first aid kit, an appointed person and information for staff.

How many first aiders do I need for 50 employees?

There is no fixed number and no HSE ratio. With 25 or more employed, HSE’s guidance expects at least one first aider even in an office; beyond that, the number depends on hazards, shifts, layout and absence cover. Fifty people on one floor with office hours might be covered by two EFAW-trained staff; fifty people across three shifts in a warehouse need first aiders on every shift.

Can an appointed person cover when our first aider is on holiday?

No. L74 paragraph 81 allows an appointed person to cover a first aider’s absence only where it is exceptional, unforeseen and temporary, and states that “absences such as annual leave do not count”. If your assessment requires a first aider, planned absence must be covered by another first aider.

Does the needs assessment have to be written down?

No. HSE says there is no requirement for it to be formal or written, but that a written record lets you show a safety representative or inspector how you decided your level of provision. In practice, write it down.

Is annual first aid refresher training mandatory?

No. HSE strongly recommends annual refresher training during the three-year certificate period but it is not a legal requirement, and a refresher does not extend the certificate. Requalification before the three-year expiry is what keeps a first aider competent in HSE’s terms.

What happens if a first aid certificate has expired?

The person is no longer considered competent to act as a workplace first aider, so your cover is reduced from the expiry date. A lapsed FAW holder can take the two-day requalification at any time afterwards, but HSE says it may be prudent to take the full three-day course where more than about a month has elapsed. The employer decides.

Does a workplace first aid kit have to comply with BS 8599?

No. HSE says to look for BS 8599 when buying a kit and, in the same guidance, that by law your kit does not have to meet the standard. There is no mandatory contents list; the contents must reflect your needs assessment. Tablets and medicines should not be kept in it.

Is online first aid at work training acceptable?

Blended learning (e-learning plus face-to-face) is accepted by HSE with additional due-diligence checks, and HSE strongly recommends that the practical elements of the syllabus are assessed by direct observation. A course completed wholly online cannot assess practical competence in that way, so it would not satisfy GEIS3 for FAW or EFAW.

Are training providers HSE approved?

No provider has been HSE approved since 1 October 2013. The employer is responsible for checking a provider’s competence, using HSE’s GEIS3 checklist: trainer and assessor qualifications, quality assurance, teaching to current Resuscitation Council UK guidelines, minimum contact hours and correctly worded certificates.

Sources

• HSE, First aid at work: The Health and Safety (First-Aid) Regulations 1981 – Guidance on Regulations, L74, third edition 2013, reissued with amendments 2015, 2018 and 2024
• HSE, Selecting a first-aid training provider: a guide for employers, GEIS3 (rev2), January 2024
• HSE, First aid – are you an employer? and Frequently asked questions on first aid
• HSE, First aid in work (small business guidance, including homeworkers and co-working spaces), updated March 2025
• Resuscitation Council UK, 2025 Resuscitation Guidelines

Choosing for yourself rather than for a workforce? Which first aid course do you need works through it from the individual’s side, and open courses run regularly across the North West and in Manchester, Bolton, Wigan, Oldham and Stockport.

Questions about your own assessment or cover? Call 0845 838 4643 or send us an enquiry and we will talk it through — there is no charge for the conversation.