This article describes the situation in Germany (German law and practice). It is a translation of the German original and is not legal or tax advice.
Martin Felux, civil engineer and industrial engineer
In the author’s assessment, an AI course for the whole office at once rarely suits every role. It works better to hold a shared kick-off on the rules, then a short module per role (managing director, project lead, site manager and office assistant) and, after two to four weeks, a session for questions. Exercises use your own workflows with invented data. At the end there is a simple record. What you have to train in your particular case is for your legal adviser to clarify.
Why split by role
The four roles use AI for different things and carry different responsibility. The managing director decides which tools are permitted. The project lead passes results on to clients. The site manager dictates on site and seldom has time for long texts. The office assistant works with drafts, appointments and filing. Putting all four in the same room means explaining much to each person that does not concern them, and leaving other things out.
In its questions and answers, the European Commission recommends taking into account the role of the organisation, the risk of the AI systems used, the staff’s existing knowledge and the context of use. In its assessment, relying only on the instructions for use of a tool remains ineffective in many cases.
The shared kick-off
Everyone first needs the same basics. They can be covered in the first hour. The answers belong in the AI policy for the office:
- Which tools are approved, and which are not?
- Which data may go into which tool?
- What can a language model do, and where does it make things up?
- Who checks before anything leaves the house?
This covers the starting questions the Commission names: what AI is, how it works, which AI the firm uses, and what the opportunities and dangers are.
The third point includes the principle from the article Why AI answers need a source reference: figures, deadlines and amounts without a source reference are not taken over. Calculations are done in a fixed program or a spreadsheet, not in the language model.
Content by role
The duration in the table is the author’s suggestion, not measured. It covers the role module including the exercise, but not the shared kick-off and not the follow-up session.
| Role | Content | Exercise with invented data | Duration (suggestion) |
|---|---|---|---|
| Managing director | Rules and approvals, data classes, data processing agreements, liability and responsibility, costs, setting up a pilot | Assess an invented tool: which data would it see, what is missing in the contract? | 1 hour |
| Project lead | Checking and releasing results, opening source references in the original, drafts for minutes and reports, limits with figures | Check an invented set of minutes against an invented recording and mark the errors | 2 hours |
| Site manager | Dictation and photos on site, preparing defects and the site diary, what does not belong in private services | Draft an invented site diary from three voice notes and correct it | 1.5 hours |
| Office assistant | Drafts for letters and minutes, filing and search, preparing appointments, passing on only after checking | Name and file an invented incoming batch, check search hits against the original | 1.5 hours |
The roles overlap. The office assistant often prepares minutes that the project lead releases. Both then practise the same route from their own side, for example along the lines of Meeting minutes with AI. On site, the template from Site diary and defects by voice and photo helps.
Exercises on your own workflows
General examples from the internet rarely fit your own workflow. It is better to have an exercise that rebuilds your workflow: your minutes header, your defects list, your filing structure, only with invented names, amounts and dates. An example for the site manager: you invent a project with three trades, dictate two minutes of site conditions and have a defects list drafted from them. The participants then look together for what the model misunderstood or added.
Allow more time for this than for presentations. Between the sessions, participants keep practising on their own workflow, using invented data for as long as the data rules for the tool are not settled. The assumption behind this: an error you found yourself is taken more seriously than a warning on a slide. The invented data serve a second purpose: nothing real can reach an unsuitable tool during the exercise.
- Shared kick-off Everyone, about 1 h: rules, tools, data
- Role module 1 to 2 h per role (suggestion), own tasks
- Exercise Own workflow, invented data, find errors
- Follow-up session After 2 to 4 weeks, about 1 h: questions from work
- Record One page per session, next to the policy
- Refresher When a tool or rule changes
Text version of the graphic
- 1. Shared kick-off: Everyone, about 1 h: rules, tools, data
- 2. Role module: 1 to 2 h per role (suggestion), own tasks
- 3. Exercise: Own workflow, invented data, find errors
- 4. Follow-up session: After 2 to 4 weeks, about 1 h: questions from work
- 5. Record: One page per session, next to the policy
- 6. Refresher: When a tool or rule changes
Start short, then follow up
After the kick-off and the role module, a follow-up session of one hour comes two to four weeks later, per role or for everyone together. There the participants clear up questions that only arose in daily work: where did the tool make something up, which task turns out not to fit, which rule is unclear?
Why not one long block at the start? That is the author’s assessment and not evidence. Many questions arise only when someone uses the tool on a task of their own, and what was heard on the training day is quickly forgotten without use. With short modules, participants practise on their workflows between the sessions and bring concrete cases with them.
Who trains, and when
Whether someone from within the firm or someone external runs the training is your decision. What matters is that the person knows the workflows of the four roles and can prepare the exercises. The shared kick-off suits a session with everyone, the role modules small groups. Do not schedule the sessions in the weeks of project closing or monthly reporting, otherwise participants will have their minds elsewhere. Whether the suggested duration is enough shows in the follow-up session, in the questions that come from daily work.
How much time the training takes
The hours in the table apply per person. The shared kick-off of one hour and the follow-up session of one hour come on top. The chart shows what that makes per role. Kick-off and role module together take two hours for the managing director, three for the project lead and two and a half each for the site manager and the office assistant. With the follow-up session that makes three, four, three and a half and three and a half hours.
-
Project leadChecking and releasing results
Kick-off and role module 3 hwith follow-up (1 h) 4 h -
Site managerDictation and photos on site
Kick-off and role module 2.5 hwith follow-up (1 h) 3.5 h -
Office assistantDrafts, filing, search
Kick-off and role module 2.5 hwith follow-up (1 h) 3.5 h -
Managing directorRules, approvals, pilot
Kick-off and role module 2 hwith follow-up (1 h) 3 h
Source: The author's suggestion, not measured; hours per person
Text version of the graphic
- Project lead: Kick-off and role module 3 h, with follow-up (1 h) 4 h (Checking and releasing results)
- Site manager: Kick-off and role module 2.5 h, with follow-up (1 h) 3.5 h (Dictation and photos on site)
- Office assistant: Kick-off and role module 2.5 h, with follow-up (1 h) 3.5 h (Drafts, filing, search)
- Managing director: Kick-off and role module 2 h, with follow-up (1 h) 3 h (Rules, approvals, pilot)
- Source: The author's suggestion, not measured; hours per person
A worked example with invented data: an office has ten staff, namely one managing director, three project leads, four site managers and two people in the office team. The kick-off costs 10 × 1 = 10 person-hours. The role modules cost 1 × 1 + 3 × 2 + 4 × 1.5 + 2 × 1.5 = 16 person-hours. The follow-up session costs another 10 × 1 = 10 person-hours at one hour per person. Together that is 36 person-hours, not counting the preparation of the exercises. Use your own hourly rate to see the cost. The figures are a worked example based on the suggested hours in this article and not a measurement.
Record of the training
In its questions and answers the Commission states explicitly that no certificate is needed. Organisations can keep an internal record of the training and other measures that took place. A record can therefore stay small: date, subject, participants, duration, material, result of the exercise. One page per session is enough, filed next to the AI policy.
The format is your decision. More important than the form is that the record is accurate and that a short session follows after a new tool or a new rule.
Article 4 of the AI Act in brief
Article 4 of the AI Act obliges providers and deployers of AI systems to take measures to support the development of the AI literacy of their staff and of other people who deal with the operation and use of AI systems on their behalf. Prior knowledge, experience, education and the context of use are to be taken into account. Training is one such measure, but not the only one.
The duty has applied since 2 February 2025. Regulation (EU) 2026/1744 entered into force on 27 July 2026 and amended Article 4: what is owed is support for the development of AI literacy, and the article prescribes no particular level for any individual, nor even a “sufficient” one (position as of November 2026). According to the Commission’s questions and answers, the national market surveillance authorities have supervised the rule since 2 August 2026. Anyone who deploys a high-risk AI system must also train staff for human oversight; according to the Commission this duty remains. The Commission collects examples from companies on its website, but according to its statements copying those examples does not give a presumption of compliance. Details of the change are in the article AI policy for the office. Whether and how Article 4 affects your business is for your legal adviser to clarify. The training described in this article is the author’s practice and not legal advice.
What you can do now
- For each role, write down three workflows in which AI is used today or is meant to be used.
- For each role, build an exercise file with invented data modelled on your real workflow.
- Create a template for the record: date, subject, participants, duration, result.
- Up to the follow-up session, note which errors and questions arose in daily work, and add exactly those to the exercises.
General information, not legal or tax advice. Your tax adviser, data protection officer or lawyer will clarify the individual case.
Frequently asked questions
Do we need a certificate for the AI training?
In its questions and answers on AI literacy, the European Commission states that no certificate is needed. Organisations can keep an internal record of the training and other measures that took place. Whether that is enough for your business is for your legal adviser or data protection officer to clarify.
How long should AI training last?
No fixed duration is prescribed. The author's suggestion, not measured: a kick-off of 1 hour, then 1 to 2 hours per role, and after two to four weeks a follow-up session of 1 hour. Whether that is enough for you shows in the exercises between the sessions and in the questions from daily work.
May we use real project data in the exercise?
Better not. Use invented data modelled on your own workflows. Then nothing can leak during the exercise, and nobody learns by the way to enter real data into an unsuitable tool.
Sources
- Europäische Kommission: AI literacy, questions and answers (European Commission: questions and answers on AI literacy under Article 4 of the AI Act) (retrieved on 13 November 2026)
- EU-Kommission, AI Act Service Desk: KI-Verordnung, Artikel 4 KI-Kompetenz (konsolidierte Fassung, Stand 27.07.2026) (European Commission, AI Act Service Desk: AI Act, Article 4 on AI literacy, consolidated version, amendments marked) (retrieved on 13 November 2026)
- Verordnung (EU) 2026/1744 (Digital Omnibus on AI), Datensatz des Amts für Veröffentlichungen der EU (in Kraft seit 27.07.2026) (Regulation (EU) 2026/1744, record of the EU Publications Office, in force since 27 July 2026) (retrieved on 13 November 2026)