In August 2026, the Shenzhen Municipal Human Resources and Social Security Bureau issued the "Notice on Publishing the Guidelines for Applying for Key Industry Areas and Projects of Work Injury Prevention for 2027," officially launching the application process for work injury prevention projects for the new year. Industry associations and large and medium-sized enterprises in industries such as construction, manufacturing, and transportation may submit applications through the Shenzhen Municipal Social Insurance Online Service System for Employer Units before September 4. Unlike previous years, this round of applications particularly encourages the use of technologies such as artificial intelligence and VR/AR to carry out scenario-based training, and promotes a precision model of "one policy per industry, one policy per enterprise." This policy trend concerns not only corporate cost control but also involves compliance obligations and legal risks in work injury prevention. As a Shenzhen lawyer who has long served enterprises, this article will interpret the key points of application from a legal perspective, helping enterprises seize the window period and use the work injury insurance fund legally and compliantly.

Legal Basis and Scope of Application for Filing Occupational Injury Prevention Projects

Work injury prevention is not an optional corporate action but a legal obligation established by the Social Insurance Law and the Regulations on Work-Related Injury Insurance. According to Article 42 of the Regulations on Work-Related Injury Insurance, the allocation, use, and management of work injury prevention funds must comply with national regulations. In this instance, Shenzhen, in accordance with the Interim Measures for the Management of the Use of Work Injury Prevention Funds (Ministry of Human Resources and Social Security Regulation [2017] No. 13), has specified that the costs of work injury prevention projects are to be covered by the work-related injury insurance fund, thereby providing enterprises with a compliant source of funding.

From the perspective of declaration subjects, the notice covers eight key industries, including construction, manufacturing, leasing and business services, wholesale and retail, transportation, warehousing and postal services, instant delivery, same-city freight, and travel. It is worth noting that instant delivery and same-city freight are included for the first time, reflecting a trend of strengthened protection of workers' rights and interests under new forms of employment. For enterprises in non-key industries but with frequent workplace accidents, the notice also reserves room for participation. Lawyers suggest that such enterprises proactively consult human resources and social security departments to confirm whether they meet the declaration conditions, so as not to miss out on policy dividends.

The types of projects for application are divided into two categories: training and publicity, with a limit of one project per category. This means that enterprises need to precisely design their projects within the limited quota. In practice, many enterprises have their applications rejected due to incomplete materials or project designs that do not meet the guidelines. Therefore, sorting out internal work-related injury data in advance and clarifying training needs are key to improving the success rate of applications.

Legal Risks and Compliance Key Points of AI and VR Training Models

The notice encourages the use of AI, VR/AR and other technologies to carry out "scenario-based" training, which aligns with the trend of enterprise digital transformation. However, the application of new technologies also brings new legal issues. First, data compliance cannot be ignored. VR training may collect employees' biometric information and behavioral data. According to the Personal Information Protection Law, enterprises are required to obtain employees' separate consent and establish a data security management system. In the event of a data breach, enterprises may face administrative penalties and civil claims.

Secondly, there is a gray area in the legal recognition of training effectiveness. The Regulations on Work-Related Injury Insurance stipulate that injury prevention training should "enhance workers' safety production awareness," but whether the interactivity and immersion of AI training can meet the standard of "effective training" may spark disputes in practice. For example, if an employee still has an accident after training, can the employer reduce its liability on the grounds of having "fulfilled its training obligations"? Lawyers suggest that when adopting AI training, enterprises should retain complete training records, including login logs and assessment results, and supplement them with offline practical drills to form a closed-loop chain of evidence, so as to address potential future disputes over work-related injury determination.

Additionally, the notice emphasizes "tailored policies for each industry and each enterprise," which requires training content to be industry-specific. If a company uses generic AI courses, it may be deemed as training that is "mere formality," affecting the acceptance of injury prevention projects and potentially resulting in costs being disallowed from fund allocation. Therefore, companies should develop customized training modules based on their industry characteristics and high-risk positions, and retain needs analysis reports for verification.

Joint and Several Liability in Collaborative Supply Chain Declaration and Contract Management

A highlight of this notice is encouraging leading enterprises to drive small, medium, and micro enterprises in collaborative applications to achieve resource sharing. This "large driving small" model helps enhance the overall safety level of the industrial chain, but it also implies legal risks. When a leading enterprise acts as the lead party and organizes upstream and downstream enterprises to jointly implement a project, if a safety accident occurs during training for small, medium, and micro enterprises, or the training quality fails to meet standards, how should responsibility be allocated?

From a contractual perspective, the lead enterprise should sign a written agreement with participating enterprises to clarify the rights and obligations of all parties, cost allocation, and liability bearing. Per Article 577 of the Civil Code, liability for breach of contract must be premised on contractual provisions. If the agreement does not specify acceptance criteria for training effectiveness and a dispute arises, the court may rule based on the principle of fairness, causing the lead enterprise to bear additional liability. Lawyers recommend that an "Workplace Injury Prevention Effectiveness Commitment Clause" should be embedded in the agreement, with quantitative indicators such as training pass rates and accident rate reduction, while also stipulating that if the project fails due to the participating enterprise's own reasons, it shall bear the relevant costs itself.

Additionally, supply chain coordination declarations involve cross-enterprise data sharing and must comply with the requirements of the Data Security Law. Participating enterprises should sign data protection clauses to clarify the purpose of data use and confidentiality obligations, avoiding commercial secret disputes arising from information leaks. For cases where a group enterprise drives its subsidiaries to file declarations, the pricing of internal related-party transactions must meet tax compliance requirements to prevent being identified as profit shifting.

Practical Operations and Lawyer's Recommendations for Enterprise Applications for Work Injury Prevention Programs

Facing the September 4 deadline, enterprises need to efficiently prepare application materials. First, a special task force should be established, with legal, safety, and human resources departments working together to review workplace injury accident data from the past three years, analyze high-incidence types and positions, and use this as the basis for project design. Second, the project budget must comply with the expenditure scope stipulated in the "Interim Measures for the Use and Management of Work Injury Prevention Funds," avoiding the mixing of routine safety expenses, otherwise it may be deemed by audits as improper use of funds.

In terms of technology selection, enterprises may give priority to partnering with qualified training institutions, leveraging their mature VR course libraries to reduce development costs. At the same time, attention should be paid to the "work injury prevention instructor training" mentioned in the notice, and cultivating internal trainers can both enhance training continuity and help build a corporate safety culture. For small and medium-sized enterprises, if they lack the capacity to apply independently, they can actively connect with industry associations or leading enterprises to join group-based training programs and share resources.

Finally, the post-application implementation phase also requires legal support. Enterprises should establish project ledgers, recording training times, personnel, content, and assessment results, and regularly report progress to the human resources and social security department. If a project needs to be adjusted for any reason, an application for modification must be submitted in a timely manner; otherwise, fee settlement may be affected. The lawyer notes here that work-related injury prevention is not only an administrative obligation, but also an investment for enterprises to reduce employment risks and enhance their brand image. Guangdong Zhiming Law Firm has long focused on the field of labor law and has assisted many Shenzhen enterprises in successfully applying for work-related injury prevention projects and building compliant training systems. If you encounter vague policy understanding, difficulties in preparing materials, or questions about contract design during the application process, you are welcome to consult us. We will provide you with customized legal solutions based on the latest policies and practical experience.