AI training for employees: obligation, cost, funding
Is AI training mandatory, what does it cost, and does the employment agency pay? Art. 4 AI Act after the Omnibus, four checked market prices and the rules of § 82 SGB III.
Sebastian LangOctober 5, 202615 min read
AI training for employees is on the list at many companies in 2026, usually with three questions behind it: Is it mandatory, what does it cost, and does the employment agency (Agentur für Arbeit) contribute? The answers shifted this summer. Since 27 July 2026, Art. 4 AI Act has applied in the version amended by the Digital Omnibus, and the legal position is more sober than some course descriptions suggest.
The need is real all the same. According to Bitkom, 70 percent of companies with 20 or more employees offer AI training and 25 percent offer none (survey of 603 companies, published on 14 September 2026). This article sorts out the law, market prices and funding, with a source for every number.
TL;DR
- Obligation: Art. 4 AI Act requires measures to build AI literacy, but no particular level, no mandatory training and no certificate. The Federal Network Agency (Bundesnetzagentur) recommends documenting the measures well.
- Cost: Four checked offers range from €10 net per person (e-learning from 1,001 participants) to €1,790 net (distance course with certificate). Our license costs €599 per license, one-time.
- Funding: Under § 82 SGB III, the employment agency can only fund approved training of more than 120 hours. Short training courses and our license on its own do not qualify.
Is AI training for employees mandatory?
In short: there is an obligation to take measures, but no obligation to provide a particular training course. Art. 4 of the AI Act (Regulation (EU) 2024/1689) has applied since 2 February 2025. Regulation (EU) 2026/1744, the Digital Omnibus on AI, amended it; it entered into force on 27 July 2026. Since then, the European Commission has described the AI literacy requirement as simplified, with a stronger role for the Commission and the Member States.
Under the new wording, providers and deployers of AI systems take measures that support the AI literacy of their staff and of other persons operating or using AI systems on their behalf. In doing so, they are to take into account the technical knowledge, experience, education and training of the staff, and the context of use. In its AI literacy Q&A (as of 27 July 2026), the Commission clarifies: no particular level is prescribed, there are no strict requirements and no mandatory training, and a certificate is not needed.
The obligation applies not only to providers but also to deployers, that is, organizations that use AI systems built by others. The Commission explicitly answers the case of a company whose employees use ChatGPT, for example for marketing copy or translations: Art. 4 applies, and the employees should be informed about specific risks such as hallucinations. Under Art. 2(10), purely personal, non-professional use by individuals is excluded.
Who enforces it, and what is at stake?
Since 2 August 2026, national market surveillance authorities have monitored compliance. In Germany, this is in principle the Federal Network Agency (Bundesnetzagentur) under § 2(1) KI-MIG (the German AI Market Surveillance and Innovation Promotion Act); the law has applied since 29 July 2026. Neither Art. 99 AI Act nor the KI-MIG names a separate fine range for Art. 4. According to the European Commission, however, the authorities can impose sanctions and other measures, proportionate and depending on the individual case. According to the Commission, this becomes more likely if an incident can be shown to trace back to missing training and guidance.
Some course descriptions and older articles date from before the Omnibus and describe the legal position more strictly. What exactly changed in the wording of Art. 4 is explained in our article AI literacy under Article 4 after the Omnibus.
Which employees need which training
Art. 4 prescribes no curriculum. The European Commission does, however, name five points an organization should consider when designing its measures:
- a general understanding of AI in the company: What is AI, how does it work, which AI do we use, what are the opportunities and dangers?
- its own role: Does the company develop AI systems, or does it use systems built by others?
- the risk of the systems in use: What do employees need to know, which risks must they be aware of?
- differences in the employees' knowledge, experience, education and training
- the context of use and the people the AI systems are applied to
Different levels are expressly allowed: the Commission considers that different training levels or learning approaches may be appropriate. This leads to a split by role. The table is our recommendation, not a legal requirement.
| Role | What they need | Basis |
|---|---|---|
| Everyone who uses generative AI (texts, translations, research) | Basic understanding, typical errors such as hallucinations, which data may go into which tool | Commission: point 1 and the ChatGPT example |
| Business teams that hand tasks to AI agents, for example with Claude Cowork | What the agent may access, when approval is needed, how results are checked | Commission: points 3 and 5 |
| Developers, for example with Claude Code | Tool-specific knowledge, plus legal and ethical aspects | Commission: people with education or experience in AI development are "normally" AI literate, depending on the tool |
| HR and areas with possible high-risk applications (applicant selection, performance evaluation, creditworthiness of private individuals) | Classification under Annex III, human oversight | Annex III no. 4 and 5(b), rules from 2 December 2027 |
| Management and AI owners | Role as provider or deployer, risk classification of the systems in use | Commission: points 2 and 3 |
| External parties who operate AI on your behalf | The same task-related AI knowledge as your own employees | Commission |
For high-risk systems, the Commission says additional measures may be relevant. For deployers of such systems, it points to Art. 26: the staff working with the system must be trained for handling the system and for human oversight. Since the Omnibus, these high-risk rules apply to Annex III systems from 2 December 2027. For a first risk classification, the AI Service Desk of the Bundesnetzagentur offers an online tool.
With agents in particular, more than the basic level is worthwhile. In the BCG study AI at Work 2026 (11,749 employees in 14 markets), 52 percent had only a limited understanding of what agents are. Our recommendation for the order: first the roles with the highest risk and the widest access, and in parallel a basic level for everyone who uses AI.
Training
One licence, two courses: Cowork and Claude Code
What AI training costs
There is no uniform market price for AI training. On 5 October 2026, we checked four public offers from DACH providers on their own websites. These are samples, not a market average.
| Provider and offer | Format | Duration | Price |
|---|---|---|---|
| TÜV Thüringen Akademie: e-learning "Unterweisung zum KI-Kompetenzerwerb im Sinne Art. 4 KI-VO" | Self-paced module with comprehension test, record in the learning management system, German and English | not stated on the page | €25 net per person for 1 to 100 participants, €20 for 101 to 500, €15 for 501 to 1,000, €10 from 1,001 |
| IHK-Akademie Koblenz: "KI-Kompetenz gemäß Art. 4 EU AI Act" | Live online one-day seminar, certificate of attendance | 1 day | from €465, exempt from VAT |
| Haufe Akademie: "Der KI-Führerschein für die Assistenz" (no. 42454) | Live online seminar, maximum 15 participants | 1 day, 9 am to 5 pm | €840 plus VAT (€999.60 incl. VAT) |
| Haufe Akademie: "Fernkurs KI-Kompetenz für den Berufsalltag mit Zertifikat" (no. 42887) | Distance course with 6 modules and e-exam, 18 months of access, graded certificate | approx. 50 hours plus 1 hour exam | €1,790 plus VAT (€2,130.10 incl. VAT) |
All prices: as of 5 October 2026, according to the provider's page.
Three things stand out in the comparison:
- The formats solve different tasks. An e-learning module, a seminar day and a distance course of around 50 hours are hardly comparable. Compare by the role from the table above, not by price per head.
- Working time comes on top. In addition to the participation fee, factor in the employees' working time. A seminar day costs one working day per person on top of the fee.
- The documentation differs. The TÜV e-learning documents participation in the learning management system, the IHK-Akademie issues a certificate of attendance, and the Haufe distance course ends with a graded certificate. Art. 4 does not prescribe a certificate.
All three providers also mention in-house formats on their pages; at the Haufe Akademie, the basis according to its own page is a day rate for up to twelve participants. When this pays off is covered in In-house training vs. open AI courses.
Our own offer for comparison: €599 per license, one-time. The license includes the training as well as the courses on Cowork and Claude Code. Details are on the pricing page.
Funding under § 82 SGB III (Qualifizierungschancengesetz)
Anyone planning AI training with funding from the employment agency ends up at § 82 SGB III, the funding of employed workers, often called the Qualifizierungschancengesetz. The requirements are in § 82(1) (as of October 2026):
- The training goes beyond purely job-specific, short-term adaptation training.
- A vocational qualification with at least two years of training was, as a rule, obtained at least two years ago.
- The person has not attended training funded under § 82 in the last two years.
- The measure lasts more than 120 hours.
- The measure and the provider are approved for funding.
Excluded are measures the employer is obliged to provide under federal or state law. The Federal Employment Agency (Bundesagentur für Arbeit, BA) adds: the 120 hours do not have to be completed in one block, and training on company-specific software, for example, is not eligible for funding. Even if all requirements are met, funding remains a discretionary decision of the employment agency (§ 82(5)).
Funding level by company size
| Company size | Employer share of course costs (§ 82(2)) | Possible BA coverage of course costs | Possible subsidy to wages (§ 82(3)) |
|---|---|---|---|
| fewer than 50 employees | should be waived | up to 100 percent | 75 percent |
| 50 to under 500 employees | 50 percent | 50 percent | 50 percent |
| 500 employees and more | 75 percent | 25 percent | 25 percent |
As of October 2026, according to § 82 SGB III and the BA page on individual funding. Three details from the law and the BA page:
- In companies with fewer than 500 employees, the employer's cost contribution should be waived for employees aged 45 and over and for severely disabled people.
- With a works agreement or a company-level collective agreement on continuing training, the employer share drops by five percentage points, and the wage subsidy can rise by five percentage points (§ 82(4)).
- The wage subsidy applies to training-related periods without work performance. The BA looks at partner companies and affiliated companies as a whole when determining company size.
How the application works
The first point of contact is the employer service (Arbeitgeber-Service) of your employment agency. The BA advises applying as early as possible before the qualification starts. If several employees take part in the same training, one collective application is enough. From 1 December 2026, BA directive 202607017 of 20 July 2026 regulates advice and funding uniformly nationwide: the employer service is responsible for employers' applications, including collective applications and the Qualifizierungsgeld (qualification allowance), and digital application via the eServices takes priority. You can search for suitable courses for your employees via the training search in the BA portal mein NOW; before booking, confirm with the employer service that both the course and its provider are approved.
What does not qualify
Short training courses do not reach the 120 hours. The Haufe distance course from the price table, at around 50 hours, also falls short. Our license on its own is likewise not eligible under § 82. Funding under § 82 is only possible for approved training of more than 120 hours that also meets the other requirements.
For larger upheavals there is the Qualifizierungsgeld (§ 82a SGB III), an earnings replacement benefit during training. According to the BA, a prerequisite is, among other things, a structural-change-related qualification need for at least 20 percent of employees (10 percent for fewer than 250 employees), set out in a works agreement or a company-level collective agreement. According to the BA, micro-enterprises are excepted: in companies with fewer than ten employees, a written declaration by the employer is sufficient under § 82a(2) SGB III. Here too, the training must exceed 120 hours, and the company bears the training costs.
Other funding
Besides § 82, we checked three routes at official bodies (as of 5 October 2026).
State programs, example Rhineland-Palatinate. The funding program "Betriebliche Weiterbildung" (in-company training), financed from the European Social Fund Plus, funds training of up to 120 hours per training course offered by accredited or recognized training providers. Private-law companies with their registered office or an independent branch in Rhineland-Palatinate are eligible. Up to 40 percent of eligible expenditure per participant is funded (up to 50 percent in the Trier region), at most €1,500 per participant and €30,000 per company and calendar year. The application must be received at least one month before the training starts; excluded are, among others, training that costs less than €100 and training booked or started before approval. Check the federal funding database (Förderdatenbank des Bundes) to see whether your federal state offers a comparable program.
European Digital Innovation Hubs. As possible support for SMEs, the European Commission names the network of European Digital Innovation Hubs, now Experience Centres for AI. According to the Commission, 9 out of 10 hubs offer AI services, including training, workshops and bootcamps.
BMAS funding guideline on AI in business and work. On 2 September 2026, the Federal Ministry of Labour and Social Affairs (BMAS) published the guideline "Produktiver und beschäftigungsorientierter Einsatz von Künstlicher Intelligenz (KI) in Wirtschaft und Arbeit" (translation: productive and employment-oriented use of artificial intelligence (AI) in business and work). It targets SMEs and their employees in particular; according to the BMAS, however, research institutions can submit proposals, until 14 October 2026, 4 pm. For training in your own company, this is not a direct route.
Documenting training
Art. 4 does not require a certificate. Internal documentation can help to record the measures taken in a traceable way. The European Commission writes that organizations can keep an internal record of their training and other guidance measures. According to the Commission, Art. 4 contains no obligation to measure employees' AI knowledge. The Bundesnetzagentur recommends documenting the measures well.
What belongs in such a record is not prescribed. We recommend these fields per measure:
- Date and type of measure (training, instruction, policy, guideline)
- Target group or role
- Content and AI systems concerned
- Participants and supporting evidence (attendance list, export from the learning system, certificate)
- Date for the next review
A template for this is part of our AI policy template: it contains a section on AI literacy under Art. 4 and a record sheet for your measures.
If you want to clarify which role in your company needs which training, talk to us for 30 minutes.
FAQ
Is AI training for employees mandatory?
Since the Digital Omnibus, Art. 4 AI Act requires measures to build AI literacy, but no particular level, no mandatory training and no certificate. You shape the measures according to role, risk and context of use. The Bundesnetzagentur recommends documenting them well.
What does AI training cost per employee?
In our sample of 5 October 2026, an e-learning course from the TÜV Thüringen Akademie costs €25 net per person (for 1 to 100 participants), a live online one-day seminar from €465 at the IHK-Akademie Koblenz and €840 net at the Haufe Akademie. A distance course with certificate costs €1,790 net. Our license costs €599 per license, one-time; working time comes on top in every case.
Does this also apply to small companies that only use ChatGPT?
Yes. The European Commission answers exactly this case: if employees use ChatGPT, for example for marketing copy or translations, Art. 4 applies, and they should be informed about specific risks such as hallucinations. Art. 4(2) obliges the Commission and the Member States to support providers and deployers in this, in particular SMEs.
Is a two-hour webinar or a YouTube video enough?
Art. 4 prescribes no format; according to the European Commission, there is no one-size-fits-all solution. What matters is whether the measure fits role, prior knowledge, risk and context of use; merely pointing to the instructions for use of an AI system can, according to the Commission, be ineffective in many cases. Our assessment: for occasional users, a short format can fit if it covers the concrete risks; for high-risk systems, the Commission says additional measures may be relevant.
Does the training have to be certified?
No. According to the European Commission, no certificate is needed; organizations can keep an internal record of their training and other measures. A certificate of attendance is still useful evidence for that record. Funding is different: for § 82 SGB III, the measure and the provider must be approved.
Does the employment agency pay for AI training (QCG, Bildungsgutschein)?
Funding is possible under § 82 SGB III, but only if, among other things, the measure and the provider are approved and the training exceeds 120 hours; depending on company size, the BA can cover 100, 50 or 25 percent of the course costs and subsidize wages at 75, 50 or 25 percent, and the decision is at its discretion. A training voucher (Bildungsgutschein, § 81(4) SGB III) can also be used for this funding of employees, which § 82(6) regulates; funding under § 81 itself, by contrast, essentially requires that the training is necessary to reintegrate someone who is unemployed or to avert imminent unemployment, or to obtain a previously missing vocational qualification. Short training courses and our license on its own are not eligible under § 82.
Sources
- European Commission, AI Literacy: Questions and Answers (as of 27.07.2026): https://digital-strategy.ec.europa.eu/en/faqs/ai-literacy-questions-answers
- European Commission, AI omnibus enters into force (27.07.2026): https://digital-strategy.ec.europa.eu/en/news/ai-omnibus-enters-force
- Regulation (EU) 2026/1744 (Digital Omnibus on AI): https://eur-lex.europa.eu/eli/reg/2026/1744/oj/eng
- Regulation (EU) 2024/1689 (AI Act), Art. 2, 4, 26, 99, Annex III: https://eur-lex.europa.eu/eli/reg/2024/1689/oj
- KI-MIG, Federal Law Gazette 2026 I No. 223: https://www.gesetze-im-internet.de/ki-mig/
- Bundesnetzagentur, AI literacy (KI-Kompetenz): https://www.bundesnetzagentur.de/DE/Fachthemen/Digitales/KI/7_Kompetenz/start.html
- Bundesnetzagentur, press release of 29.07.2026: https://www.bundesnetzagentur.de/SharedDocs/Pressemitteilungen/DE/2026/20260729_KI_VO.html
- § 82 SGB III: https://www.gesetze-im-internet.de/sgb_3/__82.html
- § 81 SGB III: https://www.gesetze-im-internet.de/sgb_3/__81.html
- § 82a SGB III: https://www.gesetze-im-internet.de/sgb_3/__82a.html
- Bundesagentur für Arbeit, funding of continuing training (Förderung von Weiterbildung): https://www.arbeitsagentur.de/unternehmen/finanziell/foerderung-von-weiterbildung
- Bundesagentur für Arbeit, individual funding of employees (Individuelle Förderung von Beschäftigten): https://www.arbeitsagentur.de/unternehmen/finanziell/foerderung-von-weiterbildung/individuelle-foerderung
- Bundesagentur für Arbeit, directive 202607017 of 20.07.2026: https://www.arbeitsagentur.de/datei/weisung-202607017_ba058267.pdf
- mein NOW, BA portal: https://mein-now.de/
- ESF Rhineland-Palatinate, funding program Betriebliche Weiterbildung: https://esf.rlp.de/berufliche-weiterbildung/betriebliche-weiterbildung/wer-wird-gefoerdert
- Federal funding database (Förderdatenbank des Bundes): https://www.foerderdatenbank.de/
- BMAS, news item of 03.09.2026: https://www.bmas.de/DE/Service/Presse/Meldungen/2026/bmas-foerdert-ki-projekte-von-unternehmen.html
- Bitkom, press release of 14.09.2026: https://www.bitkom.org/Presse/Presseinformation/Erstmals-nutzt-Mehrheit-Unternehmen-KI
- BCG, AI at Work 2026, press release of 03.06.2026: https://www.bcg.com/press/3june2026-ai-reshaping-jobs-faster-than-companies-reshaping-work
- TÜV Thüringen Akademie, e-learning on AI literacy (checked 05.10.2026): https://die-tuev-akademie.de/online-unterweisung-zum-ki-kompetenzerwerb-im-sinne-art.-4-ki-vo-der-verantwortungsvolle-umgang-mit-kuenstlicher-intelligenz-didie42
- IHK-Akademie Koblenz, KI-Kompetenz gemäß Art. 4 EU AI Act (checked 05.10.2026): https://ihk-akademie-koblenz.de/kurs/it-neue-medien/637KI_EuAIAct/ki-kompetenz-gemaess-art-4-eu-ai-act/
- Haufe Akademie, Der KI-Führerschein für die Assistenz (checked 05.10.2026): https://www.haufe-akademie.de/42454
- Haufe Akademie, Fernkurs KI-Kompetenz für den Berufsalltag mit Zertifikat (checked 05.10.2026): https://www.haufe-akademie.de/42887
Training
One licence, two courses: Cowork and Claude Code
€599 per licence, one-time. Office teams learn Cowork, engineering teams learn Claude Code.
About the author
Co-Founder · Business & Content Lead
Co-Founder of Sentient Dynamics. 15+ years of business strategy (incl. SAP), MBA. Writes about EU AI Act compliance, ROI measurement and how Mittelstand CTOs actually adopt agentic AI.
