A Report on a Desk in Buffalo: When Does the C-2F Clock Start?
It is 3:15 p.m. on a Thursday at a warehouse in Buffalo. A forklift operator slipped on a loading dock and was seen by a clinic. The clinic sent him back with a restriction and a follow-up visit. The site's HR coordinator has a C-2F open in one tab and her carrier's portal in another. She wants to know three things: which clock is running, whose clock it is, and what day she should write on her calendar.
Those questions are fair, because the Board's own materials describe the duty in more than one way. This guide quotes each statement, attributes it, and marks the places where the day basis is left open. By the end you will be able to name the C-2F's trigger and recipient, tell the employer's duty from the insurer's, and know what to confirm with the Board before you rely on a date.
What the C-2F Is and Who Receives It
The C-2F is the New York Workers' Compensation Board's form for an employer's report of a work-related injury or illness. It is a state workers' compensation document. It is not an OSHA form, and completing it does not complete anything on the OSHA side (more on that below).
The Board publishes the form at its own site (Form C-2F, NY WCB, checked 2026). We do not reproduce it here. Download the current version from the Board so you work from the text in force.
Two features of the form matter for planning:
- It carries its own deadline wording, which you should read in full.
- It includes a note about insurers that report electronically on the employer's behalf. Read that note on the current form, and confirm with your carrier and the Board whether it applies to you before you assume the paper step is waived.
What the Rule Says: Form Wording and Board Guidance
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
New York gives two descriptions of the timing. Present both, and do not collapse them.
The form's wording. The C-2F states that a work-related injury or illness must be reported within 10 days under Section 110 of the Workers' Compensation Law, or a penalty may apply (Form C-2F, NY WCB, checked 2026):
"A work-related injury or illness must be reported within 10 days (Per Section 110) of the injury/illness or be subject to a penalty."
Read the trigger closely. The form counts from the injury or illness, and the recipient is not set out in that sentence. Section 110 itself, as published by the New York State Senate, says: "Such report shall be filed within ten days after the occurrence of the accident." Neither the form nor the statute says whether the 10 days are calendar days or working days, so we do not guess. Confirm the day basis with the Board.
The Board's guidance. The Board's timely-reporting publication speaks to the employer and the insurer separately (WCB timely reporting guidance, checked 2026):
- An employer is told to notify its insurer immediately when an injury causes lost time beyond the working day or shift, or needs medical treatment beyond ordinary first aid or more than two first-aid treatments.
- The insurer must then report to the Board by the 18th day after the injury, or within 10 days after the employer learns of it, whichever is greater. The publication puts it this way: "on or before the 18th day after the workplace injury or illness occurred, or within 10 days after the employer learns of the event."
So the Board's guidance has the employer notifying the insurer immediately, which is a different recipient and a different timing from the form's 10-day sentence. These two statements describe overlapping duties from different documents. We do not pick one for you. Tell your reader, your supervisors and your carrier which source you are working from, and ask the Board how it reconciles them for your situation.
A side-by-side view
| Source | Trigger | Timing | Recipient | Citation |
|---|---|---|---|---|
| Form C-2F and WCL §110 | The injury or illness (§110: the occurrence of the accident) | Within 10 days; neither text says calendar or working days | Not stated in the sentence quoted | C-2F; §110 |
| Board guidance (employer) | Lost time beyond the working day or shift, or treatment beyond first aid | Immediately | The employer's insurer | WCB guidance |
| Board guidance (insurer) | The injury, or the employer learning of it | By the 18th day after the injury, or within 10 days after the employer learns of it, whichever is greater | The Board | WCB guidance |
If you are comparing New York against other states, the chart in first-report-of-injury deadlines by state puts each state's trigger, unit and recipient in the same format.
What You Decide
The rules above tell you when a clock may start. They do not tell you whether a particular case meets the trigger. Whether an injury needed treatment beyond first aid, whether it caused lost time, and whether it is work-related are decisions for the employer, with its carrier and advisers where appropriate.
The same is true of compensability. The Board and the carrier handle the claim process, and the employer does not adjudicate it. Nothing in this article, and nothing in a workbook or software tool, makes that call for you.
Keep these two questions apart on paper:
- Did the event meet the New York reporting trigger? (A workers' compensation question.)
- Is the case recordable on the OSHA 300 Log? (A separate OSHA question.)
A case can meet one test and not the other. Treating them as the same question is a common source of both missed reports and over-recording.
Edge Cases, and the Problem of the Knowledge Date
Which date counts as "knew"? The Board's insurer clock includes a "within 10 days after the employer learns" limb. That makes the date the employer learned of the event a fact worth recording. Write down who learned, when, and how. A supervisor's text at 2:40 p.m. and an HR email the next morning are different timestamps, and you may need to show which one you used.
Multi-state employers. A company with a site in New York and sites elsewhere cannot assume one state's day count carries over. Each state sets its own trigger, unit and recipient. For the wider picture, see multi-state employer injury reporting.
Late reports. The form says a penalty may apply. The sourced material does not state a New York penalty amount, so we do not print one. If you are asking what a late first report of injury penalty could be in New York, ask the Board or your carrier. Do not rely on a figure from another state or from memory.
Federal clocks run separately. A New York injury can also start federal OSHA clocks. Under 29 CFR 1904.39, an in-patient hospitalization, amputation or eye loss must be reported to OSHA within 24 hours, and a fatality within 8 hours (OSHA, checked 2026). Federal OSHA also has penalties behind these duties. OSHA adjusts its maximum penalties for inflation each year, so check the current figures on OSHA's penalties page; State Plans set their own. The C-2F satisfies none of these. It is a state form.
Keeping the Record Defensible
If an insurer, the Board or an OSHA inspector asks how you handled a case, the useful answer names the rule, the date you learned of the event, and what you did. A calendar entry that says "C-2F due Friday" does not show which source produced "Friday."
For the OSHA side, a recordable case must be entered on the OSHA 300 Log and the 301 Incident Report within seven calendar days of receiving information that a recordable injury or illness has occurred (29 CFR 1904.29(b)(3), eCFR, checked 2026). That clock starts from information about a recordable case, and recordability is your decision. Some employers use a state first report as the source for the 301 fields; see first report of injury as OSHA 301 and the notes on OSHA Form 301 for how far that substitution goes.
OSHA records have a five-year retention requirement following the end of the calendar year they cover (29 CFR 1904.33(a), checked 2026). Retention stays the employer's responsibility.
Where Tools Fit
Most employers handle New York the way they handle every state: a carrier portal or the Board's form, a calendar reminder, and a spreadsheet. That approach is free and familiar, and many teams build it carefully. Its weakness is that a date in a cell does not record which rule produced it or which version of the rule applied.
A deadline tracker helps with that gap. The Multi-state first-report deadline tracker is an Excel workbook that computes deadline dates from the knowledge date you enter and the jurisdiction you select, so a multi-state group can see its clocks together. You decide recordability and file with the Board, your carrier and OSHA. The workbook never submits anything to anyone.
ClaimsIntake is also building a subscription app. It will keep a versioned rule table where each row will carry an agency citation and a "last verified" date. It is not live yet, and no jurisdiction's rows have been verified. Smaller single-state employers will usually find the workbook the better fit than a subscription. You can join the waitlist if you want to hear when the app opens.
Before You Rely on a New York Date
- Download the current C-2F from the Board and read its deadline wording yourself.
- Ask the Board whether its 10-day count runs in calendar or working days, and which recipient it expects.
- Ask your carrier whether it files electronically for you.
- Record who learned of each injury, when, and how.
- Check that the same date feeds your OSHA decisions, not only your state filing.
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
Ready to see all your first-report clocks in one place? The Multi-state first-report deadline tracker computes them from the knowledge date.
