With the ‘AI Regulation’, as the EU AI Act is colloquially and aptly called, Germany is taking the first steps in the regulation of artificial intelligence together with all other EU member states. One part of the catalogue of directives: mandatory AI training that provides everyone who works with the technology with the necessary skills.
According to the Federal Statistical Office, 20 per cent of all German companies were working with AI at the end of last year. Already 20 per cent – or just 20 per cent? The ‘number of unreported cases’ in this survey is probably much higher. Interestingly, the lack of knowledge is one of the key reasons why (officially) 80 per cent of all companies do not use AI. And this is precisely where the emerging AI training obligation comes in.
Mandatory AI training: Is training compulsory for employees?
To answer your most important question in advance: Yes, AI training has been mandatory for employees since 2 February 2025. This is the result of the national implementation of the AI Act adopted at European level, which is intended to regulate the
with AI in the EU. More specifically, Article 4 of the AI Regulation regulates mandatory training:
“Providers and operators of AI-systems shall take measures to ensure, to the best of their ability, that their personnel and other persons involved in the operation and use of AI-systems on their behalf have a sufficient level of AI-competence, taking into account their technical knowledge, experience, education and training and the context in which the AI-systems are intended to be used, as well as the persons or groups of persons with whom the AI-systems are intended to be used.”
Who controls mandatory AI training in Germany?
In Germany – and every other EU country – the respective national supervisory authority will be responsible for monitoring the new AI training obligation from 2 August 2025. What this will be at German level is still up in the air. It is conceivable and likely that this task will fall to the Federal Network Agency in Germany.
Are there penalties if the training obligation is not implemented?
And what if you are reading about this for the first time and have not yet thought about AI training for your staff? Then that’s probably not a problem for the time being: the manner and exact rules are still unclear.
All that is known so far and can be gleaned from the quoted regulation text is that employees must have sufficient ‘AI expertise’ if they develop or use corresponding systems. This is intended to ensure safe and responsible use of the new possibilities.
Consequently, nothing is (yet) known about penalties and fines for offences. The EU AI Act generally provides for sanctions in the event of prohibited AI use:
- up to 35 million € or
- per cent of annual sales
Does the obligation for AI training apply to all companies?
The European AI Regulation – often abbreviated to AI Regulation – obliges both providers and operators of AI systems to have appropriate AI expertise. As AI technologies are finding their way into many, if not all, industries in the short or long term, all companies are therefore affected by the training obligation.
The regulation takes into account the different contexts in which AI systems are used. Companies must take into account the specific requirements of their industry and the type of AI systems used in order to ensure appropriate training measures for their employees.
How can the new AI training obligation be implemented?
Even if there are still no specific requirements for mandatory training in the use of artificial intelligence, you can start preparing for it now:
- Requirements analysis: Determine which of your employees work with which AI systems, to what extent and which skills are required for this. This will give you an initial overview of possible training potential and stumbling blocks.
- Training content: Consult the results of your needs analysis and consider how deeply and in which areas you could train employees. Are the basics sufficient? What about data protection expertise? Do you need in-depth knowledge of machine learning or natural language processing, for example?
- Internal vs. external: It is possible that the use of AI in your company is so extensive that you cannot train all those affected with internal resources – in this case, external service providers can help.
- Documentation and tracking: If you are already getting started with AI training, documentation is important – as soon as the requirements relating to mandatory training become concrete, you already have something in hand here.
Also remember to keep any documentation up to date. After all, there is hardly any technology that changes as quickly as AI.
Conclusion: Better to prepare sooner than later
The market for AI applications is dynamic – very dynamic. This is not least the reason for the EU’s regulatory endeavours. However, this dynamism also means that certain directives, laws and specifications have not yet been thought through and worked out in detail. The AI training obligation is a good example of this. It is clear that the obligation exists – but it is not yet clear exactly how it is to be implemented.
Jonas Wöll from the German Chamber of Industry and Commerce (DIHK) assumes that further guidelines will soon follow: ‘The European Union (EU) is currently working on guidelines for the implementation of the AI Act, which should then also contain more specific information that companies can use as a guide.’
For you, this means that you cannot yet follow the usual clear guidelines. Nevertheless, it is important that companies familiarise themselves with the topic of training, observe their duty of care and are thus prepared for the moment when the AI training obligation sets tangible guidelines.
If you have any questions, the Federal Network Agency recommends publicly funded facilities and institutions such as the Mittelstand Digital Centres or the digital association Bitkom.
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