The short answer: posting the OSHA Form 300A and submitting injury data to OSHA electronically are two different legal obligations with two different deadlines. Every covered employer must POST the 300A from February 1 to April 30. Only larger or higher-hazard establishments must also electronically SUBMIT data through OSHA's Injury Tracking Application (ITA) by March 2 under 29 CFR 1904.41. Confusing the two is a recordkeeping mistake, and each duty is independently citable.
This guide lays out the full 2026 calendar, the exact employee-count thresholds, and the dollar values at stake.
At a glance: Two separate duties. POST the certified 300A Feb 1-Apr 30 (all 11+ employee covered employers, 1904.32). SUBMIT electronically to the ITA by March 2 (1904.41) — and a 100+ employee establishment in NAICS 2381, the only construction code in Appendix B, submits 300, 301, AND 300A, not just the summary. Each is independently citable. Posting the OSHA 300A summary from February 1 to April 30 and submitting injury data electronically to OSHA's Injury Tracking Application by March 2 are two separate obligations — and a 100+ employee establishment in NAICS 2381, the one construction code in Appendix B, must submit Forms 300, 301, and 300A, not only the 300A.
The Two Obligations Are Not the Same
| Obligation | Form(s) | Deadline | Who | CFR |
|---|---|---|---|---|
| Physical posting | 300A only | Feb 1 - Apr 30 | All covered employers | 1904.32 |
| Electronic submission (ITA) | Depends on tier (below) | March 2 | Larger / Appendix B establishments | 1904.41 |
A small construction firm with 30 employees, for example, must post its 300A every year but generally does not submit anything electronically. A 120-employee construction establishment must do both — post the 300A and upload Forms 300, 301, and 300A to the ITA.
Two obligations, two deadlines — don't confuse them
Most small employers post but never submit. Each obligation is independently citable.
Obligation 1: Posting the Form 300A
The Form 300A is the annual summary of the prior year's recordable injuries and illnesses.
- Posting window: posted no later than February 1 and kept up until April 30 (29 CFR 1904.32(b)(6)).
- Where: a conspicuous place where notices to employees are customarily posted, not altered, defaced or covered (29 CFR 1904.32(b)(5)).
- Certification: a company executive must examine the log and certify the summary before it is posted (29 CFR 1904.32(b)(3)); 1904.32(b)(4) lists who counts (an owner of a sole proprietorship or partnership, a corporate officer, the highest-ranking official at the establishment, or that person's immediate supervisor).
- Coverage: employers with more than 10 employees during the last calendar year (29 CFR 1904.1), unless partially exempt under 29 CFR 1904.2 (certain low-hazard industries).
Partially exempt employers do not keep the log unless OSHA or BLS asks them in writing, but every employer covered by the OSH Act must still report a fatality, in-patient hospitalization, amputation or loss of an eye under 29 CFR 1904.39, and answer an OSHA or BLS survey request (29 CFR 1904.1(a)(1)).
Obligation 2: Electronic Submission via the ITA (1904.41)
Under 29 CFR 1904.41, certain establishments must submit injury/illness data to OSHA electronically through the Injury Tracking Application (ITA) by March 2 each year. There are three tiers:
| Tier | Threshold | What you submit |
|---|---|---|
| Tier B | 100+ employees in an Appendix B industry (from construction, NAICS 2381 only) | Forms 300, 301, and 300A |
| Large | 250+ employees, not in Appendix B | Form 300A only |
| Tier A | 20-249 employees in an Appendix A industry | Form 300A only |
The key point for contractors: only NAICS 2381 is in Appendix B. A 2381 establishment (foundation, structure and building exterior contractors) with 100 or more employees must submit the case-level detail (Forms 300 and 301), not just the summary 300A. Other construction codes submit the 300A only: at 20-249 employees through Appendix A, and at 250 or more under 1904.41(a)(1)(ii).
Count employees per establishment — the peak number of individuals employed at that establishment at any point during the calendar year — not company-wide.
The Complete 2026 Recordkeeping Calendar
| Date | Action | Authority |
|---|---|---|
| Throughout the year | Log recordable cases on Form 300 within 7 calendar days; complete Form 301 | 1904.29 |
| Jan 1 - Feb 1 | Review the year, complete and certify the 300A | 1904.32 |
| Feb 1 | Begin posting the certified 300A | 1904.32 |
| March 2 | Electronic submission deadline (ITA) | 1904.41 |
| April 30 | Last day the 300A must remain posted | 1904.32 |
| 5 years | Retain Forms 300, 300A, and 301 | 1904.33 |
Penalties for Getting It Wrong
Recordkeeping violations are documentary: an inspector can check them from the forms themselves. The maximums below are the amounts in 29 CFR 1903.15(d) for penalties proposed after January 15, 2025, still current in October 2026:
| Violation type | 2026 amount |
|---|---|
| Serious (per violation) | up to $16,550 |
| Willful (minimum) | $11,823 |
| Willful (maximum) | $165,514 |
| Repeated (minimum, a Field Operations Manual policy floor, not set by 1903.15(d)) | $4,256 |
A missing posting, an uncertified 300A, or a failure to submit through the ITA can each be cited separately.
Compliance Checklist
- Form 300 kept current; new cases logged within 7 days
- Form 301 (or equivalent) completed for each case
- 300A summary calculated and executive-certified before Feb 1
- 300A posted Feb 1 - Apr 30 in a conspicuous location
- Establishment employee peak counted to determine ITA tier
- If 100+ in NAICS 2381: submit 300, 301, AND 300A via ITA by March 2
- All forms retained for 5 years after the covered year
Hit both deadlines without the guesswork
Post-vs-submit and the ITA tier trip up even careful employers. HazComFast builds the certified 300A, checks which forms your establishment must upload by size and NAICS, and puts both deadlines on the calendar. Sort out your tier free, then keep the whole recordkeeping cycle on trial.
The standard, tools & related reading
- The standard: Recordkeeping — 29 CFR 1904
- On the job: OSHA 300A Auto-Filler · OSHA Recordability Decision Tree
- Related guides: OSHA Forms 300, 300A & 301 — Complete Guide · ITA: Who Must Submit (2026) · When Is an Injury Recordable?
- 2026 OSHA penalty schedule · penalties by state
Sources & verification (verified 2026-07-17 against osha.gov): posting duty per 29 CFR 1904.32; electronic submission tiers and the March 2 deadline per 29 CFR 1904.41 (88 FR 47254, eff. Jan 1 2024); retention per 1904.33; penalty maximums per 29 CFR 1903.15(d). General guidance, not legal advice; State-Plan states may impose stricter requirements.
Frequently Asked Questions
Is posting the 300A the same as submitting it electronically to OSHA?
No. These are two completely separate obligations. Every covered employer must physically POST the Form 300A in the workplace from February 1 through April 30. Only certain larger establishments must also ELECTRONICALLY SUBMIT their data to OSHA's Injury Tracking Application (ITA) by March 2 under 29 CFR 1904.41.
When must the OSHA 300A be posted?
The Form 300A annual summary must be posted no later than February 1 and kept in place until April 30, covering the prior calendar year (29 CFR 1904.32(b)(6)), in a conspicuous place where notices to employees are customarily posted (1904.32(b)(5)). A company executive must certify it before posting (1904.32(b)(3)).
Who has to submit injury data electronically to OSHA in 2026?
Establishments with 100+ employees in an industry listed in Appendix B to Subpart E (from construction, that is NAICS 2381 only — Foundation, Structure, and Building Exterior Contractors) must submit Forms 300, 301, and 300A by March 2 (29 CFR 1904.41(a)(2) and (c)). Establishments with 250+ employees not in Appendix B, and establishments with 20-249 employees in an Appendix A industry, submit Form 300A only (1904.41(a)(1)).
Does construction have to submit Form 300 and 301 electronically?
It depends on the NAICS. Appendix B to Subpart E lists one construction code, 2381 (foundation, structure and building exterior work), so a 100+ employee establishment in 2381 must submit Forms 300, 301 AND 300A. A general contractor (236) or heavy/civil contractor (237) of the same size submits the 300A summary, because Appendix A lists all of NAICS 23 (29 CFR 1904.41(a)(1)(i)).
What is the penalty for failing to post or submit OSHA recordkeeping forms?
Up to $16,550 per serious or other-than-serious violation and up to $165,514 per willful or repeated violation, the amounts in 29 CFR 1903.15(d) for penalties proposed after January 15, 2025, still current in October 2026.
OSHA figures and citations here come from our regulatory source-of-truth modules, last checked against the eCFR, OSHA.gov, and the Federal Register on October 5, 2026. Last reviewed October 5, 2026.
About This Article
Published by: HazComFast
Published: June 25, 2026
Last Updated: October 5, 2026
This content is for informational purposes only and does not constitute legal advice.