AI Regulation: Mandatory training for companies
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AI Regulation: Do companies have to train their employees?

Companies using AI have been required since February 2025 to ensure that all affected employees know what they are doing. This may sound like a minor detail, but it's a genuine legal obligation with concrete consequences. Rogert & Ulbrich helps you meet this requirement legally and efficiently.

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What does mandatory training mean in everyday life?

The law doesn't require every employee to become an AI expert. It's about ensuring that the people in your company who work with AI tools on a daily basis understand how these tools work – and where their limitations lie.

An employee using an AI-powered applicant tracking system should know: The system doesn't make final decisions for me. They should be able to identify errors. And they should know who to contact if something is wrong. That's exactly what's meant. Nothing more – but also nothing less.

Are you wondering if your employees already know this? We can help you identify areas where there is room for improvement.

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Who is affected by the training requirement?

This affects all companies that use or offer AI systems – regardless of size. The obligation applies not only to the IT department. It affects everyone who makes decisions or acts based on AI expenditures in their daily work.

Specifically, this means: A customer service representative who uses AI summaries to prioritize customer complaints. A sales manager who uses a scoring tool for lead evaluation. An HR manager who uses an automated resume check. All these individuals are subject to this obligation – and their employer is responsible for ensuring they are adequately qualified.

Are you unsure which of your employees are affected? We can help you pinpoint the exact number.

What should an AI training course cover?

The law does not prescribe a fixed timetable. What matters is the end result: employees must be able to use the system responsibly. As a guideline, we recommend covering the following topics:

How does the system work? Basic principles without technical overkill – enough so that errors are recognizable.
What can the system do wrong? Typical weaknesses, blind spots and limitations of the respective AI.
When does a human need to take over? Clear rules on when AI recommendations cannot simply be adopted.
What applies to affected persons? This is especially important when AI makes decisions about people.
Where do I go if I have questions or problems? A clear internal reporting process that everyone is familiar with.

Training without reference to the specific operational system will not protect you in case of doubt. Let's set this up correctly together.

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Why documentation is so important

It's not enough to simply conduct the training. You also need to be able to prove that you did. If an authority audits your company or an incident occurs, the first thing they'll request is documentation: Who was trained, when? Which system did the training cover? How was the training's effectiveness verified?

Those who don't have answers are at a disadvantage – even if the training actually took place. Structured documentation is therefore just as important as the training itself. We can help you develop a simple and reliable structure for this.

Missing documentation can be costly. Let's discuss this calmly.

What happens if companies ignore the training requirement?

The requirement has been in effect since February 2025. Anyone who has taken no action since then is already in a state of non-compliance. This means that fines are possible in the event of an official audit. And if AI-related damage occurs and the lack of training is identified as the cause, the company can be held liable – as if they had knowingly assigned an untrained employee to operate a machine.

Fines for such violations can amount to up to €15 million or three percent of global revenue. Even smaller fines can be a threat to the existence of small and medium-sized enterprises.

The obligation applies now. If you haven't taken any action yet – talk to us.

FAQs – Frequently Asked Questions about Mandatory AI Training

Does the training requirement also apply to small businesses?

Yes. The AI regulation makes no distinction between large corporations and small businesses. However, the law allows for a certain degree of proportionality: A company with five employees is not required to establish its own training department. The crucial factor is that demonstrable steps have been taken and that these are documented.

When exactly does the training obligation apply?

Since February 2, 2025. This date was not surprising – it was stipulated in the law from the beginning. Anyone who hasn't taken action by now is already behind schedule. Action should be taken now at the latest.

Is it enough to buy an online course on AI and assign it to employees?

Not necessarily. A general AI course only fulfills the requirement if it actually addresses the specific system in use and covers the relevant risks. A general "AI for Beginners" seminar provides a basic understanding – but it doesn't replace system-specific training. We can help you assess whether an existing course is sufficient.

Do external service providers also need to be trained?

Yes, if they are working on your behalf with your AI systems. The law explicitly covers external parties acting on your behalf. This should be regulated and tracked in service provider contracts.

What happens if an employee refuses the training?

As an employer, you are obligated to offer and enforce the training. This obligation to participate can be legally enshrined in employment law. Anyone who refuses the training would generally no longer be permitted to work with the AI system in question.

How detailed does the documentation need to be?

It must be traceable: Who learned what and when? In relation to which system? And was the learning outcome assessed? A simple, structured document containing this information is sufficient in most cases. The important thing is that it can be presented if necessary.

Can I outsource training completely?

Yes. External providers can conduct training – however, the responsibility for ensuring that the training took place and was sufficient remains with the company. Make sure that external training is documented and relevant to your specific system.

How often do employees need to be trained?

The law does not prescribe a fixed frequency of refresher training. In practice, refresher training is recommended when the system undergoes significant changes, new employees join the team, or new regulatory requirements arise. A one-time training session followed by no further action is unlikely to be sufficient in the long run.

What happens during an official audit?

The authorities will ask which AI systems you use, how you have classified them, and what measures you have taken to fulfill the training requirement. Those who can then provide structured documentation will have a clear advantage. Those who give improvised answers will not.

Does this obligation also apply to AI, which we only use rarely?

Yes, generally speaking. However, the required training effort is proportionate to the actual usage. Those who only use a tool occasionally and in non-critical areas don't need to develop extensive training programs. Nevertheless, basic instruction and documentation are advisable.

When should I consult a lawyer?

Ideally, consult a lawyer before you take action – not after. They can help you accurately assess your training needs, develop a legally sound concept, and create documentation that will stand up to scrutiny. If you have legal expenses insurance, check whether compliance consulting is covered.