Defibrillators (AED) at work in Germany: obligation, location and maintenance

Is a defibrillator mandatory at work?

No, there is no general legal obligation. Whether an automated external defibrillator (AED) is needed is decided by the employer in the risk assessment (Gefährdungsbeurteilung): the workplace rule ASR A4.3 counts medical devices such as the AED among the first aid supplies that may be required in addition to first aid kits, depending on the risk assessment (ASR A4.3 No. 3.4 and 4 (6)).

Buying an AED brings obligations with it. The device is a medical device, and anyone who keeps it available for use outside a healthcare facility counts as an operator under the Medical Devices Operator Ordinance (Section 2 (2) MPBetreibV). In addition, first aid supplies must be checked regularly for completeness and usability (Section 4 (5) of the Workplace Ordinance, ArbStättV). Practical guidance is given in DGUV Information 204-010 “Automated defibrillation as part of workplace first aid”.

When an AED makes sense at work

DGUV Information 204-010 lists criteria that should feed into the decision. Many companies also buy an AED without any direct obligation.

• size of the company and number of employees
• age structure of the workforce
• volume of customer or visitor traffic
• company-specific hazards, for example from electric current
• expected arrival time of the emergency medical service, for instance at remote sites or on extensive works premises

Operator duties under the MPBetreibV

A newly drafted Medical Devices Operator Ordinance has applied since 20 February 2025. Defibrillators are listed in its Annex 1 (No. 1.1), which results in these duties:

• Functional test and instruction

  ProvisionSection 11 (1) and (3) MPBetreibV

  What you have to doBefore commissioning, the manufacturer or a person authorised by it tests the device on site and instructs a person appointed by you; both are documented.

• Safety check (STK)

  ProvisionSection 12 MPBetreibV

  What you have to doat least every two years; for self-testing AEDs intended for lay users it can be dropped if you carry out regular visual inspections

• Medical device log (Medizinproduktebuch)

  ProvisionSection 13 MPBetreibV

  What you have to dorecord device data, functional test, instruction, checks, maintenance and malfunctions; keep for five years after decommissioning

• Inventory (Bestandsverzeichnis)

  ProvisionSection 14 MPBetreibV

  What you have to dorecord designation, model, serial number, year of purchase, manufacturer and location; a register kept under other rules may be used

• Maintenance

  ProvisionSection 7 MPBetreibV

  What you have to doin line with the manufacturer's instructions, for example replacing electrode pads and the rechargeable or disposable battery

The DGUV recommends appointing a suitable person to look after the AED: they replace pads and battery as specified by the manufacturer or after use, check the device regularly, act as contact person and keep the medical device log.

Location and signage

• in central places or places with a lot of foot traffic, such as the reception or entrance area
• distributed so that the AED can reach the scene in the shortest possible time even on extensive premises – several buildings or large halls often need several devices
• easily accessible in a wall cabinet or bracket; cabinets that sound an alarm when opened are an option
• marked with the safety sign E010 “Automated external defibrillator (AED)” under ASR A1.3
• shown on the escape and rescue plan, as recommended by DGUV Information 204-010
• not to be used in explosion hazard areas – AEDs are generally not explosion-protected

Where the nearest AED is located belongs on the first aid notice and in the annual safety briefing for all employees.

Checking and maintaining the AED

An AED must be ready for use at all times. Specify in the risk assessment how often and by whom it is checked, and follow the manufacturer's instructions:

1. 1

   Check the status indicator

   Most AEDs test themselves and show that they are ready for use. If the device reports an error or beeps, inform the appointed person immediately and arrange a replacement.

2. 2

   Check the electrode pads

   Adhesive pads carry an expiry date and must not be used after it – dried-out pads interfere with analysis and shock delivery. Check packaging and expiry date.

3. 3

   Check the battery

   According to DGUV Information 204-010, new batteries typically last about two to five years depending on the device, provided they are not drained by use. Check the expiry date or charge indicator as specified by the manufacturer.

4. 4

   Check accessories and location

   Are the accessories complete, is the cabinet freely accessible and is the safety sign clearly visible?

5. 5

   Document the check

   Record the date, result and name. This is how you prove the regular visual inspection – the precondition for dropping the safety check.

For AEDs intended for use by lay people, the safety checks can be dropped if the device is self-testing and the operator carries out regular visual inspections (Section 12 (2) MPBetreibV). After a failed self-test, you must restore the device's functionality without delay. Lay-user AEDs newly put into service from 1 January 2027 must additionally document their self-tests and transmit the results regularly and automatically to the operator by remote monitoring; the visual inspection can then be carried out as needed.

Training first aiders, briefing employees

In principle anyone can use an AED; at work, however, the DGUV says it should preferably be used by the company's first aiders. Basic knowledge of defibrillation is part of first aid training and refresher training, which first aiders generally repeat every two years (Section 26 (3) DGUV Regulation 1). In addition, according to DGUV Information 204-010 they must be instructed in the safe use of the device on site at appropriate intervals, at least once a year – based on operating instructions (Betriebsanweisung).

All other employees learn in the annual first aid briefing where the AEDs are located and how to reach the first aiders.

After use: device and documentation

• replace used electrode pads – they are intended for single use
• inform the appointed person; they check the battery and restore readiness for use
• save the event data recorded by the device as specified by the manufacturer – it serves the follow-up review
• record the first aid treatment in the first aid log or report form (Section 24 (6) DGUV Regulation 1)
• enter malfunctions and repeated operating errors of the same kind in the medical device log (Section 13 (2) No. 5 MPBetreibV)

Checklist: defibrillator at work

• Need assessed in the risk assessment, company doctor involved
• Locations specified, short routes even on extensive premises
• Safety sign E010 in place, locations shown on the escape and rescue plan
• Functional test and instruction at commissioning documented
• Person appointed for checks and care
• Medical device log and inventory set up
• Visual inspection carried out and documented at the specified interval
• Expiry dates of pads and battery monitored
• Safety check at least every two years, or conditions for dropping it met
• First aiders instructed on the device at least once a year, all employees informed of the locations

Free templates for this guide

As PDF and Excel, free – to use in your own company.

• First aid

  Defibrillator checklist template (PDF & Excel) for AED checks

  PDF + ExcelFree download

Frequently asked questions