BetrSichV Notfallplan: The Seven Required Contents
By Sujit Katariya, ElevatorPlus · Published 13 August · Last updated 13 August · ~9 min read · Compliance reviewed by Mr. Sumeet Katariya
In short: BetrSichV Anhang 1 Nummer 4.1 requires a written Notfallplan for every lift, with seven mandatory contents, handed to the emergency service before the lift is commissioned. Most operators treat it as a phone number on a sticker in the car. The regulation treats it as a document that has to name people, name a rescue time, and carry a full release procedure inside it.
Key takeaways
- Seven contents, lettered a) to g). Anhang 1 Nummer 4.1 Satz 4 sets out the minimum. Not five, not a template, not "contact details". Seven specified items.
- One of them is a time commitment. Buchstabe f requires "Angaben zum voraussichtlichen Beginn einer Befreiung" - details of the expected start of a release. In writing, in advance.
- The plan goes to the emergency service before commissioning. Not after handover, not on request. Satz 2 requires it to be made available to a Notdienst before the installation is put into service.
- The Notbefreiungsanleitung is inside the plan and also outside it. Buchstabe g makes the release instructions part of the Notfallplan, and Satz 5 separately requires them, with the equipment needed for a release, in the immediate vicinity of the installation before commissioning.
- A ZÜS checks it twice over. Anhang 2 Abschnitt 2 Nummer 3.3 Buchstabe a checks the plan exists before commissioning. Nummer 4.2 Buchstabe a checks it again at every Hauptprüfung, and tests whether the release instructions are plausible.
What this guide covers: why the sticker is not the obligation · what Nummer 4.1 actually says · the seven contents in full · where the plan has to be and when · the Notbefreiungsanleitung as a separate object · the two-way communication system · how the ZÜS tests it · FAQs.
A phone number on a sticker is not a Notfallplan
Walk into most lift cars in Germany and the emergency provision looks like this. A yellow button. A sticker with a number. Somewhere in the building manager's inbox, a contract with a call centre.
That is the alarm chain. It is not the Notfallplan.
The confusion is understandable, because both live under the same clause and both concern what happens when someone is trapped. But they are separate obligations with separate content, separate timing and separate consequences, and the one that gets neglected is the document, not the button. A button is visible. A missing document is only visible to a ZÜS, and by then the lift is either not going into service or is going into a report.
The pattern behind this is worth naming. Documentation obligations are consistently under-read in this sector because they produce no felt risk until an inspection or an incident. Nobody has ever noticed a Notfallplan working. People notice the button working.
The regulation is not ambiguous about which one it cares about. It specifies the button in one sentence and the document in seven lettered sub-items.
What Nummer 4.1 actually says
The provision sits in Anhang 1, headed "Besondere Vorschriften für Aufzugsanlagen", which attaches to § 6 Absatz 1 Satz 2 BetrSichV. The correct citation is Anhang 1 Nummer 4.1. Not "Betrieb von Aufzugsanlagen", which is a heading that does not exist and appears in a surprising amount of secondary material.
The structure runs like this.
Anyone operating a lift under Anhang 2 Abschnitt 2 Nummer 2 Buchstabe a must ensure that a two-way communication system is effective in the car, through which an emergency service can be reached at all times. A Notfallplan is then to be prepared and made available to an emergency service before commissioning, so that the service can respond to emergency calls promptly and appropriately and initiate proper assistance without delay. Where no emergency service is required, the plan is to be posted near the installation. The plan must contain at least the seven items below. The release instructions and the equipment needed to free trapped persons are to be provided in the immediate vicinity of the installation before commissioning.
The closing sentences extend the regime. An operator of a Buchstabe b installation — construction hoists and façade access platforms — in which a person can be trapped must ensure that person can call for help, and sentences 2 to 5 apply accordingly.
One phrase worth correcting while it is in front of us. Nummer 4.1 does not say "permanently manned location". It says the emergency service must be permanently reachable: "über das ein Notdienst ständig erreicht werden kann". The phrase "ständig besetzte Stelle" belongs to a different provision, Anhang 2 Abschnitt 2 Nummer 3.3 Buchstabe c, and it appears there qualified by "soweit erforderlich". Two different tests. They get merged constantly.
The seven contents
Here they are, verbatim, with what each one means for the person who has to produce the document.
| Item | Regulation text | What it means in practice |
|---|---|---|
| a) | Standort der Aufzugsanlage | The location of the installation. Building address is not enough on a multi-lift site. The plan is per installation. |
| b) | Angaben zum verantwortlichen Arbeitgeber | Details of the responsible employer. A named legal entity, not "the building". |
| c) | Angaben zu den Personen, die Zugang zu allen Einrichtungen der Anlage haben | People with access to all facilities of the installation. Keyholders. If nobody can open the machine room at 03:00, the plan is not true. |
| d) | Angaben zu den Personen, die eine Befreiung Eingeschlossener vornehmen können | People who can actually perform a release. A separate list from c). Access and competence are not the same thing. |
| e) | Kontaktdaten der Personen, die Erste Hilfe leisten können (zum Beispiel Notarzt oder Feuerwehr) | Contact details for first aid, with emergency doctor and fire service given as the examples. |
| f) | Angaben zum voraussichtlichen Beginn einer Befreiung | The expected start of a release. A stated time, committed in advance and inspectable afterwards. |
| g) | die Notbefreiungsanleitung für die Aufzugsanlage | The release instructions for this installation, forming part of the plan itself. |
Three of those are worth dwelling on.
Item c and item d are deliberately different lists. A facilities manager may hold every key and be entirely unqualified to bring a car to a landing. A lift technician may be qualified and hold nothing. The regulation asks for both populations because a release needs both, and a plan that names one group and assumes it covers the other has a gap in it that only shows up during an entrapment.
Item f is the one that changes the character of the document. "Voraussichtlicher Beginn einer Befreiung" is a forward-looking statement about response. Write thirty minutes and you have created a benchmark that an incident record can be measured against. Write nothing and the plan is incomplete. There is no third option in the text.
And item g means the release procedure is not a separate annex someone can promise to produce later. It is a listed content of the plan.
Where the plan has to be, and when it has to exist
Timing first, because it is the part most often missed on a new installation.
Satz 2 requires the plan to be made available to an emergency service before commissioning. The purpose clause explains why: so the service can react to emergency calls without delay and initiate appropriate assistance. A plan that reaches the call centre a fortnight after handover has not met the requirement, and the pre-commissioning ZÜS inspection under Anhang 2 Abschnitt 2 Nummer 3.1 will be looking for it.
Location next, and this is where the regulation splits.
Where an emergency service is required, the plan goes to that service. Where no emergency service has to be present, Satz 3 requires the plan to be posted near the installation. That is a genuine either/or, and it is why the sticker-in-the-car mental model misleads. In the common case the plan does not live in the building at all. It lives with whoever answers the call.
Which raises the question nobody asks at handover. Does the call centre actually hold the current version? Keyholders change. Contractors change. The person named under item d leaves. A plan handed over once at commissioning and never revised is a plan that quietly stops being accurate somewhere in year two, and there is nothing in the building to show it.
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The Notbefreiungsanleitung is inside the plan and also outside it
Satz 5 is short and it is the sentence with the most physical consequence.
The release instructions and the equipment required to free trapped persons are to be provided in the immediate vicinity of the installation before commissioning.
So the Notbefreiungsanleitung appears twice. Once as content of the Notfallplan under Buchstabe g, held wherever the plan is held. Once as a physical item near the lift, alongside the tools. Release handles, emergency keys, whatever the specific installation needs.
That duplication is intentional. The person performing the release is not necessarily the person holding the plan, and they may arrive without it.
The test applied to this document is unusual and worth noting. Both ZÜS inspection clauses ask whether the content of the Notbefreiungsanleitung is "plausibel". Not whether it exists. Whether it is plausible. A generic manufacturer procedure for a machine-room lift, sitting next to a machine-room-less installation, is present and not plausible. That is a finding.
The two-way system is a different obligation from the plan
Satz 1 requires the two-way communication system to be effective in the car, reaching a permanently available emergency service. It is about the car and the connection. The plan is about what the receiving end knows and does.
Both are needed. Neither substitutes for the other. A perfect alarm chain reaching a call centre that holds no plan produces a call handler who knows someone is trapped and does not know who has a key.
The onward-routing requirement is separate again and sits in the inspection clause rather than the operating clause. Anhang 2 Abschnitt 2 Nummer 3.3 Buchstabe c requires the ZÜS, at the pre-commissioning inspection, to check that the electrical installation is compliant and, where necessary, that the onward routing of the emergency call to a permanently manned location is assured. Note the qualifier. It applies where necessary, not universally.
One cross-border note, because the alarm chain is being re-plumbed across Europe right now. France amended its lift maintenance provisions by décret n° 2026-166 of 4 March 2026, in response to the 2G and 3G network shutdown, and the amended Code de la construction et de l'habitation article R. 134-6 now includes a check every six weeks of the correct functioning of the means of alerting and communicating with an intervention service. Germany has not made an equivalent change to Nummer 4.1. Any operator running lifts in both countries has two different obligations sitting on the same piece of hardware.
What the ZÜS is actually testing
The Notfallplan is checked at two points in the life of the installation, by a zugelassene Überwachungsstelle, which is the correct term for the inspecting body and not interchangeable with any trade name.
Before commissioning, Anhang 2 Abschnitt 2 Nummer 3.3 Buchstabe a asks whether the technical documentation, such as the EC declaration of conformity and the Notfallplan, is present, and whether the content of the release instructions is plausible.
At every Hauptprüfung, Nummer 4.2 Buchstabe a asks the same question again: whether the documents needed for the inspection, in particular the EC declaration of conformity and the Notfallplan, are present, and whether the release instructions are plausible.
Same test, twice, indefinitely. This is not a commissioning formality that expires.
What goes wrong, in the pattern we see reported across European operators, is rarely the absence of any plan. It is a plan that was written once, for a building rather than an installation, naming people who have since left, with item f left blank because nobody wanted to commit to a number, and a release instruction that was copied from a different model of lift. Every one of those is a live finding. None of them is visible from inside the car.
Frequently asked questions
How many items must a Notfallplan contain under BetrSichV?
Seven, lettered a) to g) in Anhang 1 Nummer 4.1 Satz 4. They are the location of the installation, details of the responsible employer, the people with access to all facilities, the people who can perform a release, first aid contact details, the expected start of a release, and the release instructions for that installation.
Where must the Notfallplan be kept?
It must be made available to an emergency service before commissioning. Where no emergency service is required, Satz 3 requires it to be posted near the installation. In the common case the plan is held by the emergency service rather than in the building.
When must the Notfallplan be prepared?
Before the lift is put into service. Satz 2 requires it to be prepared and made available to an emergency service before commissioning, and the pre-commissioning ZÜS inspection checks that it exists.
What is the Notbefreiungsanleitung?
The emergency release instructions for the installation. Under Buchstabe g it forms part of the Notfallplan, and under Satz 5 it must also be provided, with the equipment needed for a release, in the immediate vicinity of the installation before commissioning.
Does a Notfallplan have to state a rescue response time?
Buchstabe f requires details of the expected start of a release. The regulation does not fix a number, but it requires the operator to state one.
Is a Notfallplan needed for construction hoists and façade access platforms?
Where a person can be trapped, yes. The closing sentences of Nummer 4.1 require the operator to ensure such a person can call for help, and apply sentences 2 to 5, including the seven contents, accordingly.
Who checks the Notfallplan?
A zugelassene Überwachungsstelle. Anhang 2 Abschnitt 2 Nummer 3.3 Buchstabe a checks it before commissioning and Nummer 4.2 Buchstabe a checks it again at every Hauptprüfung, in both cases testing whether the release instructions are plausible.
Is the emergency call button the same as the Notfallplan?
No. Satz 1 requires an effective two-way communication system in the car reaching a permanently available emergency service. The Notfallplan is the separate document telling that service who to call, who can perform a release and when a release is expected to begin.
The bottom line
The Notfallplan is a small document with an unusual property: it is the only part of the German lift regime that requires the operator to write down, in advance, how quickly someone will be freed.
That is why it does not survive being treated as a sticker. A sticker cannot name keyholders. It cannot separate the people with access from the people who can perform a release. It cannot carry a release procedure specific to the model in the shaft, and it cannot be revised when the technician named in it changes employer.
The seven items are not a template to fill in once. They are seven facts about a specific installation that have to stay true, and the practical test is whether the version held by whoever answers the emergency call matches the version reality is running on.
Related reading
- Elevator service software built for European contractors
- Lift Safety Regulations: What Operators Are Actually Required To Do
- The Complete Lift Maintenance Checklist for 2026
- Elevator Maintenance Software Ireland 2026
About the author. Sujit Katariya works on European market operations at ElevatorPlus, the Elevator Business Operating System used by 200+ elevator companies across 20+ countries. Compliance reviewed by Mr. Sumeet Katariya.
Sources: BetrSichV Anhang 1, Besondere Vorschriften für bestimmte Arbeitsmittel · BetrSichV Anhang 2, Prüfvorschriften für überwachungsbedürftige Anlagen · BetrSichV § 6 Grundpflichten des Arbeitgebers · BetrSichV § 2 Begriffsbestimmungen · Code de la construction et de l'habitation, art. R. 134-6 · Décret n° 2026-166 du 4 mars 2026 · Directive 2014/33/EU on lifts and safety components for lifts
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