Workplace compliance, particularly in the fields of occupational health & safety (OHS), labour law, and employment standards, is becoming increasingly rigorous around the world.
Governments are imposing heavier fines, criminal liability (including imprisonment), and corporate sanctions in order to deter serious breaches. For employers, large corporations and SMEs alike, understanding the potential consequences of non-compliance is vital.
In this article, we highlight five countries (or jurisdictions) that stand out for having some of the highest penalties for workplace non-compliance: large fines, long potential prison terms, or both.
These jurisdictions serve both as cautionary examples and as benchmarks: if you have operations or vendors there, you’ll want to know what the “worst‐case” exposure can be.
Highest Penalties for Workplace Noncompliance – The Top 5
1. Australia
Australia has among the most severe penalty regimes in the “industrial manslaughter” context – that is, workplace deaths caused by gross negligence or recklessness.
For example, under the new laws in New South Wales (NSW) the maximum penalty for an individual has been raised to 25 years’ imprisonment, and for a body corporate A$20 million. (nsw.gov)
In the Northern Territory (NT), the maximum is even more extreme: life imprisonment for an individual and fines of around A$11.44 million for a company.
These laws apply to “persons conducting a business or undertaking” (PCBUs) or officers of PCBUs whose gross-negligent failures lead to a worker’s death. The message is clear: the worst workplace safety failures can lead to full criminal liability for individuals, not just companies.
From a compliance perspective: if you operate in Australia (especially high‐risk sectors like construction, mining, manufacturing) you need to treat OHS not just as an insurance matter but as potentially criminal.
2. Hong Kong
n the context of occupational safety & health, the jurisdiction of Hong Kong recently increased its penalties significantly.
Under the Occupational Safety and Occupational Health Legislation (Miscellaneous Amendments) Ordinance 2023 (effective 28 April 2023) the maximum penalty for breaches of general duties by an employer increased to HKD 10 million (~USD 1.28 million) on indictment, and up to 2 years’ imprisonment for individuals. (InsightPlus)
Under summary conviction the fine can be up to HKD 3 million and 6 months’ imprisonment for willful contravention. (Global Compliance News)
Because Hong Kong is a major international business hub, these penalties matter: companies and their directors can be exposed to very high fines and prison risk for serious OHS failures. It underscores that even jurisdictions not typically “top of mind” for the harshest penalties are stepping up enforcement.
3. Singapore
The city-state of Singapore has a well-developed workplace safety and health regulatory framework under its Workplace Safety and Health Act (WSH Act).
The penalties for non-compliance are meaningful: for example, failing to comply with a remedial order or stop-work order under the Act can incur fines of up to SGD 500,000 and up to 12 months’ imprisonment (or both) for individuals, and up to SGD 1 million for organisations (repeat offenders) in certain circumstances. (mom.gov.sg)
As of 1 June 2024, the maximum fine for more serious WSH offences (such as ones involving death, serious injury or risk thereof) increased from SGD 20,000 to SGD 50,000 in specified regulatory provisions. (VietnamPlus)
While the figures may not reach the tens of millions in other jurisdictions, Singapore’s clarity of individual liability (the Act applies to persons conducting business, officers, etc.) and the real prospect of imprisonment make it a compliance hotspot for multinationals.
4. Hungary
Though less widely reported than some Anglophone jurisdictions, Hungary has recently taken significant steps to ramp up its penalty regime for occupational health & safety violations.
From 1 March 2024, the Hungarian Government raised the upper limit of fines to HUF 100 million (approx. EUR 250,000 depending on exchange rates), with multipliers for serious accidents (e.g., 10× in case of a fatality) for employers. (kcgpartners.com)
While the law does not yet specify the exact maximum imprisonment term (or at least not widely publicised in that source for workplace fatalities), the enhanced fine levels and the fact there is criminal admin availability shows that Hungary is moving toward heavy penalties in this space.
For companies operating in Central & Eastern Europe (CEE), Hungary’s increasing penalty regime is a signal that “cheap-compliance” assumptions may no longer hold.
5. USA
Although the US may not always have the highest global dollar-fine levels, it remains significant in terms of enforcement and per-violation maximums.
Under the Occupational Safety and Health Administration (OSHA) regime (federal level), as of January 15, 2025, the maximum penalty for a “willful or repeated” violation is USD 165,514 per violation. (OSHA)
While this is less than some other jurisdictions, the number of inspections, enforcement actions and the cumulative exposure (for large firms with many violations) makes the U.S. regime highly consequential. Furthermore, in certain prosecutions the fines reach multiple millions of dollars (for example BP in one case was fined US$81.3 million in the past). (OSHAPro)
In addition, there is increasing pressure at state level (and public reputation risk) beyond the federal minimums. For many multinational firms headquartered or operating in the U.S., the enforcement risk is real.
While the U.S. may not have the single highest fine seen globally, it nevertheless makes this list because of its deep enforcement history and potential for criminal as well as civil sanctions.
Conclusion
In an era where workplace fatalities, serious injuries, psychosocial risks, and labour-rights failures are under heightened scrutiny, the cost of non-compliance is no longer just reputational. It can be existential for businesses and individual officers.
Across the five jurisdictions we looked at:
- Australia leads globally in terms of potential imprisonment for individuals (up to 25 years or greater) and multi-million dollar corporate fines.
- Hong Kong has recently escalated penalties to HKD 10 million plus 2 years jail for serious OHS breaches.
- Singapore enforces substantial fines (SGD 500k to 1m) plus jail risk.
- Hungary is rapidly increasing its administrative and criminal penalty regime in the Central/Eastern European region.
- The USA, though lower in dollar maximums comparatively, has deep enforcement and consistent risk of large fines and possible jail in the most serious cases.
What does this mean for employers and compliance professionals?
- Duty holders matter: In many jurisdictions, individuals (directors, officers, managers) face direct criminal liability—not just the company.
- Worst-case exposure should be modelled: Don’t just look at “average fine”, model “catastrophic scenario” (worker death, gross negligence) and plan accordingly.
- Global operations require global compliance frameworks: What may be “small risk” in one country is major liability in another.
- Practical prevention always beats post-incident penalty: Investing in safety systems, audits, training, risk-assessments pays off—not just for workers, but for organisational survival.
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