The Shenzhen Municipal Human Resources and Social Security Bureau recently issued the "Notice on the Release of the Application Guidelines for Key Industry Sectors and Projects for Workplace Injury Prevention in 2027," officially launching the application process for 2027 workplace injury prevention projects. According to the notice, large and medium-sized enterprises and industry associations in eight major industry sectors, including construction, manufacturing, and transportation, may submit applications through the Shenzhen Municipal Social Insurance Online Service System for Employers before September 4. Of particular note, this notice explicitly encourages the use of artificial intelligence, VR/AR, and other technologies to carry out scenario-based training, and promotes a precision training model of "one policy per industry, one policy per enterprise, and one training per position." The expenses required for the projects will be covered from the workplace injury insurance fund in accordance with the "Interim Measures for the Administration of Workplace Injury Prevention Fee Usage."

From a legal perspective, work injury prevention is not only a reflection of corporate social responsibility but also a statutory obligation under the framework of the Regulations on Work-Related Injury Insurance and the Production Safety Law. The release of Shenzhen's application guidelines this time provides eligible enterprises with a compliant pathway to utilize the work injury insurance fund to enhance workplace safety standards. This article will analyze, from a lawyer's practical perspective, the key points for applying for work injury prevention projects, the legal basis, and the compliance risks that enterprises should be aware of, helping enterprises make good use of policy benefits and reduce legal disputes arising from work-related injuries.

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

The establishment of work injury prevention projects directly stems from the provisions of Article 12 of the Regulations on Work Injury Insurance regarding the use of work injury insurance funds, which clearly stipulate that the extraction ratio and usage measures for work injury prevention expenses shall be formulated by the social insurance administrative department of the State Council jointly with the financial and other departments. This time, 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) and the relevant implementation rules of Guangdong Province, included the expenses of work injury prevention projects in the expenditure items of the work injury insurance fund, which constitutes a statutory expenditure item.

The notice designates key industries including construction, manufacturing, leasing and business services, wholesale and retail, transportation, warehousing and postal services, as well as emerging industries such as instant delivery, intra-city freight, and ride-hailing. These industries generally share characteristics of labor intensity, high workforce mobility, and high-risk working environments. It is worth noting that the notice does not exclude other industries—as long as enterprises experience frequent workplace injuries, they are equally encouraged to apply. This reflects the universality of the workplace injury prevention system.

The lawyer reminds that workplace injury prevention projects are not corporate benefits, but rather the specific implementation of statutory systems. Before applying, companies should verify whether they belong to key industries or meet the criteria of "frequent workplace accidents," and confirm that their social insurance contribution status is normal; otherwise, the application may be rejected due to disqualification of the applicant. In addition, the types of projects available for application are divided into two categories—training and publicity—with a limit of one application per category. Companies should choose based on their actual needs to avoid duplicate investment.

AI-Empowered Work Injury Prevention Training: Legal Boundaries and Compliance Requirements of Innovative Models

The biggest highlight of this application guidelines is the explicit encouragement of using AI, VR/AR and other technologies to carry out "scenario-based" training. From a legal perspective, this innovative model aligns with the requirement of Article 28 of the Work Safety Law that production and business entities shall provide work safety education and training to their employees, and through technical means, it can more realistically simulate accident scenarios, thereby improving the relevance and effectiveness of training.

However, technology applications must comply with legal provisions on data security and personal information protection. When enterprises use AI and VR systems for training, they may involve collecting personal data such as employees' biometric information and behavioral trajectories, and must strictly adhere to the "minimal necessity" principle and the informed consent rules under the Personal Information Protection Law. As a pioneer region in data legislation, Shenzhen enterprises should also pay attention to the compliance requirements of the Shenzhen Special Economic Zone Data Regulations to ensure the legality of training data collection, storage, and use.

Additionally, evaluating the effectiveness of workplace injury prevention training is also a legal concern. According to the Interim Measures for the Use and Management of Workplace Injury Prevention Funds, performance evaluations must be conducted after project implementation, and the results will affect subsequent fund allocations. Lawyers advise that when introducing AI training systems, companies should simultaneously establish quantifiable evaluation mechanisms, such as training completion rates, assessment pass rates, and comparative accident rate data, to prepare for social security department inspections. If workplace injuries occur due to perfunctory training, companies not only face administrative penalties but may also bear adverse consequences in workplace injury compensation lawsuits.

"One Industry, One Strategy; One Enterprise, One Approach" — the Linkage of Work-Related Injury Determination in Precision Training

The notice emphasizes the implementation of precision training under the policies of "one policy per industry, one policy per enterprise, and one training per position," which is closely related to the "three work" elements (work time, work place, and work reason) in the judicial practice of work injury identification. In disputes over work injury identification, whether job-specific training was received often serves as key evidence in determining whether the employer has fulfilled its safety guarantee obligations.

For example, in the construction industry, falls from heights are a common type of accident. If a company conducts VR simulated fall experience training for workers in high-altitude positions and retains training records, then in the event of an accident, during work injury determination and subsequent litigation, the company can use this to prove that it has fulfilled the education and training obligations stipulated in the Work Safety Law, thereby reducing the risk of being found negligent in management. Conversely, if the training is merely a formality and lacks job-specific differentiation, lawyers representing workers in work injury compensation cases may argue that the company is at fault and demand a higher compensation ratio.

Shenzhen this time encourages a "park-industry-enterprise-team" four-level linked group training model, as well as core supply chain enterprises leading upstream and downstream small, medium, and micro enterprises to jointly apply. This model legally forms a pattern of "joint training and shared responsibility." However, lawyers remind that if an accident occurs during collaborative training, liability determination is still based on labor relations; the leading enterprise does not automatically bear workers' compensation liability for employees of other enterprises merely because it organized the training. Therefore, enterprises participating in joint applications should sign written agreements to clarify the training organizer, cost sharing, and liability boundaries, so as to avoid legal disputes.

Practical Operations and Risk Prevention for Enterprise Application of Work Injury Prevention Projects

The application window is from now until September 4, and time is tight. Enterprises should submit materials as soon as possible through the Shenzhen Municipal Unit Social Insurance Online Service System. Application materials generally include a project feasibility report, implementation plan, budget details, and so on. Lawyers advise enterprises to set up a special task force composed of legal, security, and finance departments to ensure materials are compliant.

Expense allocation is a core concern. According to regulations, project expenses are allocated from the work-related injury

In addition, the notice encourages large enterprises to lead small, medium, and micro enterprises in applying, and to share training bases and expert resources. This model is beneficial to small and medium enterprises, but attention must be paid to intellectual property ownership issues. For example, if the scope of use is not agreed upon for training courses and VR content provided by leading enterprises, copyright disputes may arise. Lawyers suggest clearly specifying in the cooperation framework agreement the authorization scope, usage period, and ownership of derivative works for the sharing of training resources.

Finally, work injury prevention and employment compliance are inseparable. Even after a successful application, enterprises must still implement daily workplace safety management; otherwise, in the event of a major work-related injury accident, the social security department may suspend the disbursement of project funds. Enterprises should integrate work injury prevention projects with their internal workplace safety responsibility systems to establish a long-term mechanism. Guangdong Zhiming Law Firm has long provided enterprises with services in work injury prevention compliance, labor dispute resolution, and legal risk control for workplace safety, helping enterprises build a comprehensive legal protection system covering everything from training to accident handling.

Conclusion: Workplace injury prevention is a legal obligation, and even more so, a source of corporate competitiveness.

Shenzhen's 2027 annual work injury prevention project application is both a policy dividend and a test of legal compliance. By leveraging AI and other technologies to innovate training models, enterprises can not only enhance safety management standards but also share costs through the work injury insurance fund. However, legal risks run through the entire process of application, implementation, and evaluation, and any oversight at any stage may lead to administrative liability or civil compensation risks. It is recommended that enterprises seize the application window period and leverage the expertise of professional lawyers to ensure compliant project implementation, truly realizing the legislative purpose of "prevention first" and building dual safeguards for both enterprises and employees.