Can the 270-hour limit be exceeded in peak season?

No. Under Law No. 4857 total overtime may not exceed 270 hours in a year. Busy periods have to be managed through capacity planning.

Does a worker on a trial period need SGK registration?

Yes. Insurance starts on the first day of work and the start-of-work notice must be filed before that date; a trial period is not an exception.

Can a single serious finding stop an order?

That depends on the brand's policy. Findings such as child labour, forced labour or falsified records require urgent action at many brands.

8 October 2026 · 3 min read

Most common findings in subcontractor workshops

The most common findings in subcontractor workshops are excessive overtime, unregistered workers, missing age documents, blocked exits, missing machine guards, inadequate first aid, wage and overtime calculation errors, unauthorised subcontracting and a missing risk assessment.

Why do subcontractor workshops have more findings?

Subcontractor workshops run on short lead times, swinging order volumes and small administrative teams, so gaps in records and safety show up more often than in main factories. Most problems come from missing systems, not bad intent.

The table below summarises the findings auditors most often raise in textile supply chains, why each one matters and how to fix it for good. The legal bases are Labour Law No. 4857, Occupational Health and Safety Law No. 6331 and Social Security Law No. 5510.

What are the most common findings and how are they fixed?

Finding	Why it matters	How to fix it
Excessive overtime	Under Article 41 of Law No. 4857 overtime may not exceed 270 hours a year and needs the worker's consent; normal weekly hours are capped at 45 (Article 63). Excessive hours also count among the indicators of forced labour.	Keep a per-person annual overtime log, spot anyone approaching 270 hours early, plan capacity against orders and collect consents in writing.
Unregistered (undeclared) workers	Under Article 8 of Law No. 5510 a worker must be registered with SGK before starting work. Undeclared work is a finding no brand accepts.	Compare everyone on the floor with the SGK register; file the start-of-work notice before the first day; never let anyone work unregistered, trial periods included.
Missing age documents	Under Article 71 of Law No. 4857 children under 15 may not be employed. Without a document the auditor cannot verify age.	Take a copy of the ID at hiring and keep it on file; list workers under 18 separately and keep them away from night work and heavy jobs.
Blocked or locked emergency exits	In a fire or a panic this costs lives. In amfori BSCI, clear and marked escape routes are a crucial question.	Keep exits unlocked throughout the shift, ban storage in front of them and run a daily checklist.
Missing machine guards	The main cause of finger and eye injuries on sewing and cutting machines.	Fit needle, belt and pulley guards; forbid their removal; check after every maintenance.
Inadequate first aid	Response is delayed when an accident happens. In amfori BSCI, qualified first aid being available at all times is a crucial question.	Have a certified first-aider on every shift, check the kit regularly and post emergency numbers.
Wage and overtime calculation errors	Overtime must be paid at 50 percent above the normal hourly rate (Article 41 of Law No. 4857). Underpayment directly affects what workers are owed.	Reconcile time records with payroll every month; show overtime as a separate line on the payslip; hand out payslips.
Unauthorised subcontracting	A brand that does not know where its product is made cannot manage the risk; many codes of conduct forbid it outright.	List every workshop you use, get the brand's written approval and stop passing work on without it.
No risk assessment, or an outdated one	Under Article 10 of Law No. 6331 the employer must carry out or commission a risk assessment.	Prepare the risk assessment with an occupational safety specialist and update it whenever machines, layout or processes change.

What happens once a finding is raised?

The auditor records the finding in the report and asks the site for a corrective action plan (CAP). For each finding the plan should state the root cause, the action, the person responsible and the date.

A lasting fix addresses the root cause. Excessive overtime, for example, is usually a capacity-planning or order-management problem; correcting the time records alone does not solve it, and creates a risk of falsified records. Closure is verified with evidence such as photos and documents, or with a follow-up audit.

Frequently asked questions

Can the 270-hour limit be exceeded in peak season?: No. Under Law No. 4857 total overtime may not exceed 270 hours in a year. Busy periods have to be managed through capacity planning.
Does a worker on a trial period need SGK registration?: Yes. Insurance starts on the first day of work and the start-of-work notice must be filed before that date; a trial period is not an exception.
Can a single serious finding stop an order?: That depends on the brand's policy. Findings such as child labour, forced labour or falsified records require urgent action at many brands.