The ruling on NR-1 psychosocial risks suspends sanctions for a further 90 days, but keeps companies’ obligations in force.
NR-1 psychosocial risks are once again at the centre of the corporate debate. On 24 September 2026, Justice André Mendonça, of the STF (Brazilian Federal Supreme Court), extended the suspension of fines on the matter. The extension is valid for a further 90 days and also covers infraction notices and other administrative sanctions. The decision, however, kept the substantive obligations under the rule in force. In other words, companies remain required to identify, assess and prevent factors such as harassment, work overload and excessive pressure.
What has changed in the enforcement of NR-1 psychosocial risks
Ordinance No. 1,419/2024, issued by the Ministry of Labour and Employment, amended NR-1 (Regulatory Standard No. 1, on occupational health and safety). Since then, the standard requires employers to include psychosocial factors in their occupational risk management. In practice, this covers harassment, work overload, excessive pressure to meet targets and similar situations.
Bodies representing the education, healthcare and retail sectors have challenged these provisions before the STF. They do not dispute the importance of mental health at work. The central issue is another one: the lack of objective criteria for identifying, assessing and managing such risks. For this reason, the reporting Justice had already suspended the enforcement effects of the rule at an earlier stage.
The new decision now extends that suspension for a further 90 days. In the meantime, labour inspectors may not impose fines, issue infraction notices or apply other sanctions based on the challenged provisions. The obligations themselves, however, remain valid and enforceable.
Who is affected by the decision
The suspension applies to employers in general, and not only to the entities that filed the lawsuits. Companies of all sizes and in all sectors are therefore, for the time being, shielded from administrative penalties based on these provisions.
On the other hand, the decision does not address the employer’s civil or labour liability. A working environment that is harmful to mental health continues to create a risk of individual and collective claims. The suspension of fines therefore does not operate as a shield against claims for damages or for constructive dismissal (rescisão indireta).
Likewise, compliance with the NR-1 obligations may itself serve as evidence of due diligence in any future dispute. This point is of particular interest to companies with a compliance structure and internal audit procedures.
Time limits and exceptions
The extension runs from 24 September 2026 and lasts 90 days. The decision did not set an exact end date, nor did it announce any further extension. There is also no indication of exceptions based on company size or economic sector.
According to the published wording, the STF may reinstate the enforcement effects once the ongoing negotiations are concluded and the matter is finally adjudicated. There is as yet no information as to who is taking part in these talks or what their subject matter is. It is therefore advisable to monitor the progress of the lawsuits and any measures adopted by the Ministry of Labour and Employment.
The management of NR-1 psychosocial risks is no longer a purely labour law issue and has become part of companies’ governance agenda. Further analyses on the subject are available in other legal news commented on by the firm.