OSHA ITA FAQs: Submission Dates, Coverage, and Corrections for 2026 Data
2026 data is due in OSHA's ITA by March 2, 2027, and coverage depends on each establishment's headcount and NAICS code, not company size.
Quick answer
2026 data is due in OSHA's ITA by March 2, 2027, and coverage depends on each establishment's headcount and NAICS code, not company size. Missed the date? OSHA still expects covered establishments to submit, and the ITA accepts prior-year data through December 31.
The ITA deadline is easy to miss when establishment eligibility is checked too late.
The rule in plain English
Covered establishments submit injury data to OSHA's Injury Tracking Application (ITA) by March 2 each year for the previous calendar year; for 2026 data that is March 2, 2027 (29 CFR 1904.41). Three groups must submit: establishments with 250 or more employees that must keep records (300A data); establishments with 20 to 249 employees in an industry listed in Appendix A to Subpart E (300A data); and establishments with 100 or more employees in an industry listed in Appendix B (300A data plus 300 and 301 case data). Headcount means every individual employed at any time in the prior year, including part-time, seasonal, and temporary workers, and every submission includes the establishment's EIN.
ITA coverage at a glance
- 250 or more employees at any time last year, and the establishment keeps records: submit 300A data.
- 20 to 249 employees and an industry on Appendix A to Subpart E (for example agriculture, utilities, construction, manufacturing, wholesale trade, and many retail, transportation, warehousing, healthcare, and hospitality codes): submit 300A data.
- 100 or more employees and an industry on Appendix B (for example many food, metal, and furniture manufacturing codes, hospitals, nursing homes, warehousing, and grocery and department stores): submit 300 and 301 case data as well as 300A data.
- Partially exempt under 1904.1 or 1904.2: no routine submission unless OSHA notifies you in writing.
- Deadline: March 2, 2027 for 2026 data. OSHA's ITA Coverage Application gives an official answer for a specific NAICS code.
What this looks like in practice
Treat January 2 through March 2 as the active filing window, and submit required data through the ITA. Most ITA problems are establishment data problems: an old NAICS code, a parent-company EIN, or a headcount measured at the wrong level. The fix is to decide coverage per establishment in the fall, clean the EIN, NAICS, and address data then, and leave only validation and submission for February.
At the director level the question is less about one case and more about whether every site applies the rule the same way, with evidence you could show an inspector.
The mistake to avoid
Teams assume a missed March 2 deadline means the portal no longer accepts the data.
The ITA submission is built from the certified 300A (and, for Appendix B establishments, the 300 and 301), so every correction to the log has to be reconciled with what was submitted.
Edge cases worth checking
- OSHA says covered establishments that missed the deadline still need to submit through the ITA.
- For 300 and 301 case data, OSHA excludes employee names and addresses and health care provider details from the submission (1904.41(b)(9)).
Example
An EHS manager fields three questions in one week. Does the 180-person plant with no injuries submit? Yes, a zero-case 300A. Does the 15-person sales office? No, it had fewer than 20 employees. The plant's EIN changed in a reorganization: can last year's establishment profile be reused? Yes, after updating the EIN on the existing profile.
Step by step
- Confirm coverage for each establishment.
- Prepare the data.
- Submit through the ITA.
- Keep the confirmation and any correction notes.
What to keep in the case file:
- The coverage decision for each establishment: peak headcount, NAICS code, and which appendix applies
- The EIN used by each establishment
- The submitted file or payload and the ITA confirmation
- Notes on any corrections made after submission
Where 300log helps
300log validates EIN and NAICS formats, produces ITA-ready CSV files for the 300A and for case data, and can authorize auto-filing of 300A data once you connect an ITA API token.
For a quick answer without an account, use the free ITA coverage checker.
Frequently asked questions
Who has to submit to the OSHA ITA?
Establishments with 250 or more employees that keep records, establishments with 20 to 249 employees in Appendix A industries, and establishments with 100 or more employees in Appendix B industries (which also submit 300 and 301 case data).
When is the ITA deadline for 2026 data?
March 2, 2027.
Do temporary and part-time workers count toward the thresholds?
Yes. Each individual employed in the establishment at any time during the year counts as one employee, including part-time, seasonal, and temporary workers (29 CFR 1904.41(b)(2)).
Does electronic submission replace posting the 300A?
No. Posting the certified 300A from February 1 to April 30 is a separate duty under 29 CFR 1904.32.
Sources
Primary regulation and agency guidance this article relies on.
- [1]OSHA Injury Tracking Application informationOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]OSHA Injury Tracking Application frequently asked questionsOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.41: Electronic submission requirementsOccupational Safety and Health Administration · osha.gov(opens in a new tab)
Written and reviewed by the 300log Editorial Team. Guidance, not legal advice: confirm edge cases with OSHA or counsel.