Recently, the Shenzhen Municipal Human Resources and Social Security Bureau issued the "2027 Guidelines for Key Industries and Project Application in Work Injury Prevention," officially launching a new round of work injury prevention project applications. For industries and enterprises with higher work injury risks, such as construction, manufacturing, and instant delivery, this is both a policy dividend and an implicit test of legal compliance. As a lawyer who has long served enterprises, I believe this application is not just an administrative procedure, but also a "health check" for corporate compliance management.

Application Qualifications and Materials: Don't "Step on a Mine" at the Very First Step

The notice clarifies that the applicant entities are industry associations and large and medium-sized enterprises in key industries, and enterprises in other industries with frequent work-related accidents may also participate. However, how are "large and medium-sized enterprises" defined? In practice, the "Standards for the Classification of Small and Medium Enterprises" is often referenced, but social security departments may have more detailed criteria. If an enterprise misjudges its own size and submits an application that does not meet the qualification requirements, at best the materials will be returned, and at worst it may affect subsequent expense payments.

In addition, application materials must be submitted online, and it is essential to ensure the information is true and complete. If false materials are provided to defraud work injury prevention fees, according to the Social

Project Execution and Payment: The "Hidden Reefs" in Contract Terms

The declared projects are divided into training projects and publicity projects. Each enterprise may submit at most one of each, with an implementation period of 2026–2027. The key point is that training projects must complete the planned number of participants by 2026; otherwise, fee settlement may be affected. Fees are covered by the work-related injury insurance fund, with 70% advance payment made after stage acceptance, and the remaining balance paid after the 2027 evaluation passes.

Two legal risks are involved here: first, execution progress. If the enterprise fails to complete the training on time due to internal adjustments, the social security agency has the right to refuse the final payment and even recover the advance payment. Second, contract management. The enterprise needs to sign a service contract with the contractor (e.g., a training institution) to clarify the rights and responsibilities of both parties, avoiding acceptance failure caused by the third party's poor performance. In practice, I have seen cases where the enterprise could not hold the other party liable because the contract did not specify acceptance standards. Therefore, it is recommended to incorporate delivery clauses consistent with social security requirements into the contract and retain implementation records.

Post-hoc supervision and auditing: the "last mile" of compliance

Occupational injury prevention projects are not merely "filed and done with." Social security handling institutions will conduct phased acceptance checks and follow-up visits, and enterprises are required to cooperate by providing training sign-in sheets, promotional materials, expense vouchers, and other documents. If audits uncover issues such as misappropriation of funds or inflated participant numbers, in addition to recovering the funds, the enterprise may also be placed on a list of untrustworthy entities, affecting its eligibility for future applications.

From a lawyer's perspective, this is an opportunity for enterprises to establish long-term compliance mechanisms. I recommend that enterprises create project-specific archives, keeping complete records from application to acceptance, and conduct regular internal audits. If a rectification notice is received, it should be addressed proactively, with legal support sought when necessary to avoid escalation of administrative disputes.

A Few Suggestions for Shenzhen Enterprises

The work injury prevention program is an important measure by the government to support enterprises in reducing employment risks, but compliance is the prerequisite for enjoying the benefits. Enterprises should: First, plan early and designate dedicated personnel to handle the application; Second, leverage professional expertise to review materials and contracts; Third, strictly implement the program and keep complete records.

Guangdong Zhiming Law Firm has long focused on the field of enterprise compliance in Shenzhen, and can provide enterprises with legal services such as consulting on work-related injury prevention project applications, contract review, and dispute resolution. If you have any questions, feel free to contact our team of lawyers to help you move forward in compliance and develop with peace of mind.