Register · digital

Can the safety register be kept in digital form?

In brief

Yes. The French Labour Code allows the safety register (registre de sécurité) and inspection reports to be kept and stored on any medium, including digital (article R4323-27). The medium must show every mandatory entry without difficulty or risk of alteration, be presented like the paper version and kept as long: in general five years, and at least the last two inspections.

Beware of a namesake: this page does not cover the fire safety register of establishments open to the public (ERP), which follows other rules. It covers the Labour Code register in which the employer records the inspections of its machines, aerial work platforms, forklifts and lifting appliances. For the overall picture (intervals, report, findings, register), see VGP and lifting equipment: the complete guide.

What the texts say

No template is imposed. According to INRS (the French occupational safety institute), the regulations set mandatory entries but "impose no particular format", and registers "may exist in paper or dematerialised form". The relevant articles:

ArticleWhat it provides
R4323-25The result of periodic general inspections (vérifications générales périodiques, VGP) is recorded in the safety register(s)
R4323-26External inspector: their report is attached to the register; failing that, the register states the date of the inspection, the date the report was delivered and where it is archived
R4323-27The register and reports may be kept and stored on any medium, under the conditions of article L8113-6
L8113-6 and D8113-2Another medium, notably computer-based, is allowed if equivalent control guarantees are maintained
D4711-2Documents are dated and state the identity of the person or body in charge of the inspection and of the person who carried it out
D4711-3Unless special provisions apply: documents of the last five years and, in any case, of the last two inspections
L4711-5An option, not an obligation: merge separate registers into a single register, if this makes storage and consultation easier
R4323-101Same rule for personal protective equipment subject to inspection

The four conditions for a digital register

Article D8113-2 frames any "substitute medium" (support de substitution) for a paper register. For a fleet manager, that means four questions:

  1. Are all entries there? For each inspection: the machine, the date, the body and the inspector, the result, and the report (or its delivery date and archive location).
  2. Can they be read without difficulty? An inspector must find a machine's last VGP without knowing your tool.
  3. Are they safe from alteration? Keep reports in the PDF you received, and avoid a file where a line can be deleted without a trace.
  4. Is the register presented and kept like paper? It must be viewable during a visit, and throughout the retention period.

Attaching the inspectors' reports

For lifting appliances and accessories, the order of 1 March 2004 (article 3) provides for a provisional report at the end of the inspection, then the final report within four weeks. The head of the establishment enters the results in the register without delay; according to circular DRT 2005-04, this entry reflects the conclusions of the reports, which are attached to it.

Digitally, "attaching" means linking the report PDF to the machine's line. Also note the date the final report was received and the follow-up to any observations: according to INRS, repair work is justified by invoices or by notes written on the report. See also how to read a VGP report.

Retention and presentation: to whom, and for how long

D4711-3 covers inspection documents of the last five years and, in any event, those of the last two inspections. A digital register is kept as long as the paper one (D8113-2). In construction, INRS recalls that safety registers are kept on the site or, if that is impossible, at head office.

The register and reports must be available to:

WhoBasis
The labour inspectorate, during its visitsL4711-3
Prevention officers of the social security bodies (Carsat)L4711-3
Members of the works council (comité social et économique, CSE)L4711-4; presented at the meeting following receipt of the documents (R2315-23)
The occupational physician and, where applicable, OPPBTP (the construction industry prevention body)L4711-4

Moving from paper to digital without gaps

  1. List the machines subject to inspection, with a unique identifier (fleet number) matching the one on the reports.
  2. For each one, gather the reports of the last five years, and at least the last two.
  3. Scan them into legible PDFs and link each report to the machine and the inspection date.
  4. Compare the dates with the required intervals: a missing VGP must show up now, not on inspection day.
  5. Note in the paper register the date from which tracking continues digitally.
  6. Keep the paper register and originals for the retention period: the texts cited do not say a scanned copy replaces them.
  7. Decide who enters data and who checks it, and plan a regular export or backup.

Spreadsheet or software: what each does

The texts impose no tool. A well-kept spreadsheet can be enough for a small fleet; our VGP tracking spreadsheet is free. Its limits grow with the number of machines:

NeedSpreadsheetTracking software
List of machines and VGP datesYesYes
Attached reportsLinks to files, which break if a folder movesPDFs stored on the machine's record
Alert before the due dateFormatting you monitor yourselfAutomatic alerts
Change historyLimitedDepends on the tool
Showing an inspectorFile to sort or printFile by machine, site or fleet

What Trackary does, and what it does not do

Trackary, VGP tracking software, shows on its Compliance screen the status of each machine and each inspection: up to date, due soon, overdue, missing. The compliance file produces a compliance register in PDF (fleet, selection, machine or site), with the inspection reports attached in a ZIP and a time-limited share link that shows whether it was opened. With the “inspection body report upload” module, hidden by default and to be switched on, the inspection body can upload its reports itself, for you to approve. Trackary costs €14 excl. VAT per active machine per month (€11 above 50 machines), unlimited users, with a 30-day free trial, no credit card required.

Trackary helps you keep and present this information. It is not in itself "the" legal register, does not carry out VGP inspections, certifies nothing and does not guarantee compliance: the employer remains responsible for the entries, the attachments and retention.

Bring each machine's reports, due dates and statuses together, then present them as one file: try Trackary free for 30 days. Free trial ↗

Frequently asked questions

Is a digital safety register legal in France?

Yes. Article R4323-27 of the Labour Code allows the safety register and reports to be kept and stored on any medium, under the conditions of article L8113-6: complete entries, readable, with no risk of alteration.

Is a safety register in Excel valid?

No text imposes a tool. The file must contain every entry, point to the inspectors' reports and present no risk of alteration (D8113-2). With a large fleet, that is often where it reaches its limits.

Is there a free safety register?

Yes. OPPBTP offers a free 16-page safety register template in PDF, to print and fill in, which can be kept in digital as well as paper form.

Should the old paper register be kept?

Yes, as a precaution, for the retention period: five years and at least the last two inspections (D4711-3). The texts cited do not provide that a scanned copy replaces the original.

Is an electronic signature required?

The articles cited here do not require one. They require dated documents, the identity of the body and the inspector (D4711-2) and a medium with no risk of alteration (D8113-2).

Try Trackary on your fleet.

€14 excl. VAT per active machine per month, €11 above 50 machines. 30-day free trial, no credit card required.