AI training obligation: what the AI Act means for personnel development

What does the AI Act say about mandatory AI training?

The EU AI Act, which came into force on August 1, 2024, introduces a training obligation for companies that offer or operate AI systems from February 2, 2025.

The most important points of this AI training obligation are:

Scope of the training obligation

• Companies must ensure that their employees have sufficient AI skills.

• The training obligation applies regardless of company size or sector.  

• This affects both providers that develop AI systems and companies that use AI systems developed by third parties.

Content of the training courses

• employees need to understand the correct use of AI.

• Training should take into account technical knowledge, experience, education and the context of AI use.

• AI competence comprises skills, knowledge and understanding of the use of AI systems, including opportunities, risks and potential damage.

employees affected by the AI training obligation

• developers need detailed training on technical and ethical requirements.

• Managers must be trained in compliance, responsibility and risk management.

• users of AI systems should receive basic training.

• data privacy and compliance officers require special training.

Documentation and consequences

• Companies must document that their employees have been trained accordingly.

• Direct penalties for breaches of the training obligation are not provided for in the AI Act, but could be introduced by the member states.

• Incorrect use of AI systems can have legal and economic consequences. Through targeted training, you can ensure the safe and legally compliant use of AI in your company.

The AI training obligation presents companies with the challenge of implementing suitable training measures in good time in order to meet the legal requirements and deal responsibly with AI. However, mandatory training is not just an annoying obligation, but also a great opportunity: companies that invest in their employees' qualifications at an early stage secure their ability to innovate in addition to regulatory compliance. Use mandatory training as a strategic advantage in the digital transformation.

Where do companies currently stand when it comes to implementing mandatory AI training?

This year, the Haufe Akademie once again asked HR developers from medium-sized and large companies about the topics that will concern them most in 2025. In addition to the perennial issue of leadership development, the mandatory development of AI skills is naturally a key topic.

But to what extent have companies already trained their employees in artificial intelligence expertise? Are they all already fulfilling their training obligations under the AI Act?

When asked about the current status of implementation, it became clear that, despite the obligation to develop AI skills that has been in force since February, there are still difficulties with concrete implementation. Almost half of the companies surveyed have either not yet started implementation or have not yet dealt with the requirements of the EU AI Act. In view of the AI training obligation that has now also come into force in Germany, this is a surprising figure - it is time to actively tackle implementation.

Who implements the AI training obligation and how in the company?

According to our survey, e-learning formats are the method of choice for implementing the AI training obligation. While the desired format is clear in its digital form, the responsibility remains unclear in many companies.

Both HR development and the IT or development department are usually involved. Around a quarter of organizations have formed their own AI project team. However, almost as many respondents stated that they do not know who has the lead responsibility for this topic. This lack of clarity could be a key factor in the lack of implementation of mandatory AI training.