Missed the OSHA 300A deadline? What to do next

Missing the March 2 OSHA 300A electronic-submission deadline is fixable. The wrong move is to ignore it and hope the gap disappears.

OSHA's ITA FAQ says establishments that missed the timely filing deadline must still submit their data if they are required to do so. So the recovery plan is simple: confirm whether the establishment is covered, submit the right records, clean up the posting and retention pieces, and keep proof of what happened.

1. Confirm whether this establishment had to submit

Do this by establishment, not by company. The electronic-submission rule depends on the establishment's size, industry, and recordkeeping status.

Under 29 CFR 1904.41, common covered groups include:

• Establishments with 250 or more employees that must keep OSHA records.
• Establishments with 20 to 249 employees in designated high-hazard industries.
• Establishments with 100 or more employees in certain industries that must submit additional 300 and 301 data.

If you operate multiple locations, one site can be covered while another is not. Use the filing checker before you spend time preparing a filing for the wrong location.

2. Submit the 300A even though it is late

If the establishment is covered, submit the prior calendar year's data through OSHA's Injury Tracking Application. OSHA supports the web form, CSV upload, and API submission paths. For a late filing, the key is to get a complete, accurate submission into ITA instead of waiting for a reminder or citation.

Before you submit, compare the 300A totals against the underlying OSHA 300 log:

• Total recordable cases should reconcile to the case rows.
• Days away and restricted/transfer days should match the case details.
• The establishment name, EIN, industry classification, address, employee count, hours worked, and data year should be complete.
• A company executive should certify the annual summary.

3. Do not forget the posting requirement

Electronic submission does not replace workplace posting. Under 29 CFR 1904.32, the annual summary is posted from February 1 through April 30 in a place where employee notices are normally posted. Only the 300A summary is posted, not the detailed 300 log.

If the posting window has already passed, still keep a copy of the certified 300A with your records and document what you did. 29 CFR 1904.33 requires retaining the log, annual summary, and 301 incident reports for five years.

4. Keep evidence of the recovery

Save the ITA confirmation, the 300A you certified, the source 300 log, and a short note explaining when the late submission was completed. If OSHA follows up, you want the answer to be factual and fast: the establishment was reviewed, the filing was submitted, and the records are retained.

5. Prevent the same miss next year

Put these dates on the calendar:

• January 2: ITA typically opens for the prior year's data.
• February 1: post the 300A summary.
• March 2: electronically submit covered data.
• April 30: remove the posted summary after the posting window ends.

RegFile tracks the deadline, drafts the 300A from your records, runs consistency checks, and files after you authorize. If you are not sure whether this year's requirement applies, start with the filing checker.

Start the filing checker ->

This is informational, not legal advice — verify against your adopted rule.