OSHA's Electronic Injury and Illness Reporting Rule: What Employers Need to Know in 2026

OSHA requires certain employers to submit injury and illness recordkeeping data electronically each year through the agency’s Injury Tracking Application (ITA). The rule has changed twice since it was first adopted, so it’s worth being clear about what’s actually required today, not what was proposed a decade ago.

A short history, since this rule has moved more than once

OSHA first adopted electronic injury and illness reporting in 2016, requiring many employers to submit data from Forms 300, 300A, and 301 through the newly created ITA. In January 2019, OSHA rolled part of that back: it rescinded the requirement for establishments with 250 or more employees to electronically submit the more detailed Form 300 (Log) and Form 301 (Incident Report) data, citing worker privacy concerns, while keeping the Form 300A (Annual Summary) submission requirement in place.

That wasn’t the end of it. On July 21, 2023, OSHA published a new final rule that reinstated and expanded the requirement to submit Form 300 and Form 301 data electronically, this time targeting establishments with 100 or more employees in designated high-hazard industries. The rule took effect January 1, 2024, and the first submissions under it were due March 2, 2024.

What’s required as of 2026

Coverage depends on establishment size and industry (NAICS code), evaluated at the establishment level, not the company as a whole:

• Establishments with 250 or more employees (in industries required to keep OSHA injury and illness records) must electronically submit their Form 300A Annual Summary data every year.
• Establishments with 20 to 249 employees in the industries designated in Appendix A to Subpart E of 29 CFR Part 1904 must also electronically submit their Form 300A data annually.
• Establishments with 100 or more employees in the high-hazard industries designated in Appendix B to Subpart E of 29 CFR Part 1904 must electronically submit information from their Form 300 Log and Form 301 Incident Report, in addition to Form 300A. This is the requirement that was rescinded in 2019 and restored, with a new 100-employee threshold, by the 2023 rule.
• Establishments are not required to submit electronically if their peak employment in the prior calendar year was 19 or fewer, or if their industry is on the fully exempt list in Appendix A to Subpart B, regardless of size.
• Every submission must include the establishment’s legal company name.

If you’re not sure which category your establishment falls into, OSHA’s ITA Coverage Application will tell you based on your NAICS code and employee count. Establishments under a State Plan should confirm requirements directly with that State Plan, since some states have their own rules.

The deadline

Electronic submissions are due by March 2 each year, covering data from the previous calendar year. If your establishment misses that date, OSHA still expects the submission and allows late filing through December 31 of that year; missing the deadline doesn’t excuse the obligation.

Why this matters beyond compliance

OSHA publishes establishment-specific injury and illness data submitted through the ITA, and uses it to target enforcement and outreach toward establishments and industries with elevated injury rates. Getting your recordkeeping and submission process right isn’t just about avoiding a citation for the paperwork; inaccurate or incomplete data can also put your establishment on OSHA’s radar for the underlying hazards. Quantum Compliance’s recordkeeping tools help EHS teams track OSHA-recordable cases year-round and generate ITA-ready 300A summary data, 300 log entries, and 301 incident reports without a scramble every March.