HSE's latest annual report gives a reassuring headline. In 2024/25 it completed 246 prosecutions, 96% of them ended in a conviction, and the courts imposed more than £33 million in fines. That is close to the £34.9 million of 2019/20. Read on its own, it suggests enforcement in Great Britain has barely changed.
It has changed a great deal. The fine total held steady for reasons that have little to do with how much enforcement HSE does, and the figures that would show the change are getting harder to find. Below is my read of the official numbers, set against the US and Germany, with a clear line between what the data shows and what it doesn't.
The headline, and what sits under it
In 2015/16, HSE and the Crown Office in Scotland took 683 health and safety cases to a verdict. In 2024/25 HSE completed 246 prosecutions. That is a fall of about two-thirds in under a decade.
Notices tell the same story. HSE issued just over 4,400 notices in 2024/25: about 3,200 improvement notices and 1,200 prohibition notices. The year before it issued over 7,000, so that is a 37% drop in a single year, and the annual report gives no reason for it. Prohibition notices are the ones that stop dangerous work on the spot. Between 2012/13 and 2018/19 HSE issued roughly 2,800 to 3,400 of them a year. It now issues less than half that.
Capacity has moved the same way. HSE missed its own target of 14,000 proactive inspections in 2024/25, completing just over 13,200. Its inspectors and visiting health and safety staff fell from 1,059 full-time equivalents in March 2020 to 975 in March 2025, even though HSE as a whole grew, mostly because of the new Building Safety Regulator.
| Year | Prosecution cases | Total fines | Average fine per conviction | HSE notices |
|---|---|---|---|---|
| 2014/15* | 659 | £18.1m | £29,197 | 9,446 |
| 2015/16 | 683 | £35.1m | £54,447 | 8,776 |
| 2016/17 | 577 | £68.0m | £125,221 | 9,507 |
| 2017/18 | 511 | £71.6m | £147,263 | 8,975 |
| 2018/19 | 395 | £55.2m | £149,901 | 8,936 |
| 2019/20 | 343 | £34.9m | £107,343 | 6,922 |
| 2020/21 (provisional) | 199 | £26.9m | £145,290 | 2,929 |
| 2023/24 | 248 | not published | not published | over 7,000 |
| 2024/25 | 246 | over £33m | about £140,000 (my estimate) | over 4,400 |
Up to 2020/21: HSE's official enforcement statistics (cases with a verdict, HSE and COPFS). 2023/24 and 2024/25: HSE's annual reports, which give rounded figures. *2014/15 uses the older counting basis, before HSE's 2019 revision, so it is not strictly comparable.
The fall in prosecutions started well before COVID. Cases dropped every year from 2015/16 to 2019/20. At the time, HSE linked this to time spent on defence challenges to the new sentencing guideline, more hearings to settle disputed facts at sentencing, and a large number of inspectors in training. It said its prosecution policy had not changed.
The fall is also far steeper than the fall in harm. In 2025/26, 126 workers were killed in work-related accidents in Great Britain, provisionally the lowest rate outside the pandemic years. That is good news, but deaths have not fallen by two-thirds, and HSE itself says the long-run decline has slowed. Safer workplaces alone don't explain where the prosecutions went.
Why the fine total held up
The answer is the Sentencing Council's health and safety guideline, in force since 1 February 2016. It changed two things.
First, harm is judged on the risk created, not the injury caused. A company can receive a large fine where nobody was hurt. Second, the fine is read from a table based on the company's turnover. For a large organisation (£50 million turnover or more), starting points run from £10,000 to £4 million, with ranges up to £10 million, and courts can go higher for very large firms. For a micro business, the highest starting point is £250,000. The same conduct at the top level of culpability and harm therefore starts 16 times higher for a large firm.
It worked as intended. The average fine per conviction went from about £29,000 in 2014/15 to about £150,000 in 2018/19. By 2017/18, 45 cases were fined more than £500,000, against 5 cases of £500,000 or more in 2014/15. The Sentencing Council's own 2019 assessment found fines rose sharply for larger organisations, as planned, and also rose for small ones, which it had not expected. Reading from its charts, the median fines in HSE cases moved roughly like this:
| Organisation size | Median fine before the guideline | Median fine after |
|---|---|---|
| Large and very large | about £25,000 | about £370,000 |
| Medium | about £20,000 | about £100,000 |
| Micro and small | about £20,000 | about £45,000 |
Approximate values read from charts in the Sentencing Council's 2019 assessment. Before the guideline about 65% of organisations were fined under £20,000; afterwards about 31% were.
That explains the shape of the trend. Total fines peaked at £71.6 million in 2017/18, when the guideline was fully in force and HSE was still completing around 500 cases a year. They have fallen since because there are fewer cases, not because courts became softer. HSE said exactly that about the 2018/19 drop. Today's £33 million is about two and a half times the 2012/13 total, from roughly 40% of the case volume.
In my view this is the most misread number in British health and safety. A steady fine total looks like steady enforcement. In practice it mostly reflects which large organisations happened to be sentenced that year.
The average hides the typical case too. Over £33 million across about 236 convictions works out at roughly £140,000 each, but most defendants are smaller firms paying tens of thousands of pounds. HSE has never published a median fine.
One case can move a whole year
Because fines scale with turnover, a single sentencing can shift the annual figure. In April 2025 Cambridgeshire County Council was fined £6 million, plus £292,461 in costs, over the Cambridgeshire Guided Busway, where three people died and a teenage cyclist suffered life-changing injuries. Against a year of about £33 million, that one case is roughly 18% of the total. In 2020/21, a year with only 199 cases, seven fines were £1 million or more.
Two more cautions apply. Fines arrive years after the harm: the busway deaths happened in 2015, 2018 and 2021, and the fine came in 2025. So a year's total mostly describes decisions about incidents from several years earlier. And "UK fines" depends on which regulator you count. The biggest recent UK safety penalty, £14 million against Transport for London and Tram Operations Ltd for the 2016 Croydon tram crash, was brought by the rail regulator, ORR. Network Rail's £6.7 million fine for the Carmont derailment went through the Scottish courts. Neither appears in HSE's figures.
The data itself is getting thinner
The last edition of HSE's "Enforcement statistics in Great Britain" was published in December 2021 and covered data to March 2021. Since then HSE has treated enforcement figures as management information, published only as rounded numbers in its annual report and accounts. In practice that means:
- no total fines figure at all for 2021/22, 2022/23 or 2023/24
- no breakdown by industry since 2020/21
- no average fine, and no split between HSE and Crown Office cases
- no local authority prosecution figures since around 2016, and no local authority notice figures since 2018/19
The last reliable sector picture showed construction and manufacturing dominating both prosecutions and notices. Construction drew the most prohibition notices, which fits immediate risks such as work at height. The guideline's effect showed clearly there too: the average construction fine per conviction rose from £28,199 in 2015/16 to £127,261 in 2018/19. Nothing comparable has been published for the four years since.
I find this the most worrying part. Health and safety management rests on measuring, reviewing and acting on data. It is hard to hold anyone to that standard when the enforcement data itself has become less detailed.
How the UK compares
Comparing totals across countries is tempting and mostly misleading, because the systems work differently.
United States. Federal OSHA issues administrative penalties per violation, capped at $16,550 for a serious violation and $165,514 for a willful or repeated one. There was no inflation increase in 2026: the 2025 government shutdown meant the inflation figure the formula needs was never produced, so the 2025 amounts still apply. Since July 2025, the largest discount for small employers covers firms with up to 25 staff instead of 10, and a new discount rewards fixing a hazard on the spot. US penalties are proposals that are often reduced on settlement, while UK fines are final court sentences. Federal inspections fell 12.6% in FY2025, to 30,273, and reported OSHA data shows compliance officer numbers falling from 812 to 629 in a year. A willful violation that kills a worker is only a misdemeanour under federal law, and criminal prosecutions are rare.
Germany. Germany publishes no national total of health and safety fines in euros at all; the federal government confirmed this in its answer to a parliamentary question in December 2025. Individual fines are capped: up to €30,000 for breaching an enforceable order under the Occupational Safety and Health Act, and €5,000 for breaching an ordinance. Volume is high, though. In 2024 the state labour inspectorates carried out 137,996 inspections, and the statutory accident insurers carried out 525,289 more. By my count they issued about 5,350 fine notices between them. From 2026 each German state must inspect at least 5% of workplaces a year, and the first evaluation is due in 2027.
| Great Britain (HSE) | United States (federal OSHA) | Germany | |
|---|---|---|---|
| Type of sanction | Criminal court fine | Administrative penalty per violation | Administrative fine notice |
| Ceiling | No limit; turnover-based guideline | $16,550 serious, $165,514 willful or repeated | €30,000 or €5,000 under the OSH Act |
| Headline figure | Over £33m in fines (2024/25) | No official annual penalty total | About 5,350 fine notices (2024); no euro total |
| Recent direction | Prosecutions flat at about 250; notices down 37% in a year | Inspections down 12.6% (FY2025) | Inspections and fine notices up from 2022 to 2024 |
The common thread is that publication is shrinking in more than one place. The UK downgraded its enforcement statistics. In December 2025 OSHA removed its public page listing penalty cases of $40,000 or more. Germany counts actions but not amounts. Whatever their size, the fine totals governments publish tell you more about how each system is built than about how safe workplaces are.
What the numbers show, and what they don't
| If you read… | It does show | It does not show |
|---|---|---|
| "Fines are holding steady" | Total fines are about where they were in 2019/20 | Steady enforcement: cases are down about two-thirds since 2015/16 |
| "Fines are much bigger since 2016" | Average and median fines rose several times over, especially for large firms | That every business pays large fines: about a third were still fined under £20,000 |
| "Fines went up (or down) this year" | When a few large cases happened to be sentenced | A change in enforcement effort |
| "Fines reflect how bad incidents were" | Culpability, the risk created and the company's size | Actual harm: proof of injury is not required |
| "UK fines dwarf the US and Germany" | UK courts can fine large firms far more per case | That the UK enforces more: Germany inspects far more often |
What I'd watch next
If you track enforcement, watch the figures without a pound sign: prosecution cases, prohibition notices and inspections per inspector. They show how much is actually happening. Read the fine total as a measure of who was in court, not how hard the regulator is working.
HSE's 2025/26 annual report should appear around November 2026. A law firm's write-up of HSE's annual general meeting in July 2026 mentions around 250 prosecutions, an 88% conviction rate and £34.5 million in fines. I'd wait for the official report before relying on those figures. If the 88% is confirmed, it would be the lowest conviction rate in the published record, which has sat between 92% and 96%.
For duty holders the practical message is uncomfortable but simple. Your chance of being prosecuted has fallen. If it does happen, especially to a larger organisation, the fine is far bigger than it used to be, and it will arrive years after the event, when the people who made the decisions may have moved on. That is a poor reason to relax, and a good reason to fix the risk now.
Sources
- HSE Annual Report and Accounts 2024/25 and 2023/24
- HSE, Enforcement statistics in Great Britain, 2021, 2019 and 2018 editions (archived), and the prosecutions and notices data tables
- HSE enforcement statistics page, fatal injuries 2026 and fatal injuries overview
- Sentencing Council health and safety guideline and its 2019 assessment summary
- HSE: Cambridgeshire County Council fined; ORR on Croydon and Carmont
- OSHA: 2026 penalty memo, July 2025 penalty reductions, enforcement summary; inspector numbers as reported by Business Insurance; $40,000+ case page removal reported by J.J. Keller
- Germany: SuGA 2024 report (Bundestag print 21/3310), government answer 21/3538, §25 ArbSchG and §21 ArbSchG
- 2025/26 figures from HSE's July 2026 AGM as reported by Gordons LLP (not yet confirmed by HSE)
Figures marked "my estimate" or "by my count" are my own arithmetic from the official figures, not published statistics.