Online safety training in Germany: what e-learning may and may not replace

Is digital safety instruction allowed?

Yes – as an aid, not as a substitute for every instruction. Digital safety instruction (digitale Unterweisung) via e-learning, video or app is permitted if it relates to the specific workplace, employees can ask an instructor questions and their understanding is checked. A pure self-study course without a contact person is not enough, and for hazardous substances, biological agents and protective equipment against fatal hazards, German rules require oral instruction or exercises.

Several formats are meant: learning modules on a computer or smartphone with comprehension questions, explainer videos, presentations to read, or a live session via video conference. What matters is not the medium but whether the instruction meets the requirements for content, dialogue and relevance to the workplace.

What the ArbSchG and DGUV Regulation 1 require

Section 12 of the Occupational Safety and Health Act (ArbSchG) does not set a format. However, instruction must be sufficient and appropriate, contain instructions and explanations specifically geared to the workplace or area of responsibility, and take place during working hours – on recruitment, when tasks change and when new work equipment or technology is introduced, each time before work starts. Section 4 of DGUV Regulation 1, the basic accident prevention regulation of the German statutory accident insurance, adds: repeat at least once a year, document it, and communicate the relevant regulations and rules in an understandable way.

How this works in practice is described in DGUV Rule 100-001, June 2025 edition. For digital formats, these points are decisive:

• Employees must be able to ask the instructors questions.
• Simply handing over instruction content for self-study is not enough.
• The employer must make sure the content has been understood – for example through comprehension questions, having the employee demonstrate the procedure or observing how they work.
• Where electronic aids are used, additional practical teaching of work processes and behaviour may be necessary.
• Managers check whether instruction is effective.

Where e-learning is not enough

Some rules explicitly set the format. In these cases, a digital module can prepare and refresh knowledge but cannot replace the prescribed part:

• Hazardous substances

  RequirementOral, based on the operating instruction (Betriebsanweisung), workplace-specific, before starting work and at least once a year; content and date recorded in writing and signed (Section 14 (2) of the Hazardous Substances Ordinance, GefStoffV)

  Consequence for digital formatsAccording to TRGS 555 no. 5.3, electronic media serve to support and prepare – oral instruction remains mandatory

• Biological agents

  RequirementOral, based on the operating instruction, workplace-specific, before starting work and at least once a year, confirmed by signature (Section 14 (2) and (3) of the Biological Agents Ordinance, BioStoffV)

  Consequence for digital formatsDigital module only as a supplement, oral part at the workplace

• PPE against fatal hazards or permanent damage to health

  RequirementCommunicate the user information as part of instruction with exercises (Section 31 DGUV Regulation 1)

  Consequence for digital formatsPractise putting on, checking and using it – for example a full-body harness or respiratory protection

• Work equipment

  RequirementTask-related instruction before first use, then at least once a year; date and names recorded in writing (Section 12 (1) of the Industrial Safety Ordinance, BetrSichV)

  Consequence for digital formatsTheory possible digitally, demonstrate operation at the machine and have it practised

• Young workers

  RequirementBefore employment starts and, before first working on machines, at dangerous workplaces or with substances hazardous to health, also on their particular hazards; at least every six months (Section 29 of the Youth Employment Protection Act, JArbSchG)

  Consequence for digital formatsShow the particular hazards at the workplace; digital modules are suitable for refreshers

The DGUV's specialist committee on organisation also points out that electronic media tend to be general, whereas instruction relates to the specific workplace. Work processes and behaviour still have to be practised in real life. Digital formats are only partly suitable for work in complex hazardous situations, on machines or for putting on respiratory protection and other protective equipment.

Records: when is a digital confirmation enough?

DGUV Regulation 1 requires instruction to be documented – according to DGUV Rule 100-001, it prescribes neither a particular format nor a signature. A digital confirmation via a personal user account meets this duty, provided it is clear who was instructed on which content and when. A signature makes proof easier but is not mandatory here.

Some state regulations are stricter: for hazardous substances and biological agents, content and date must be recorded in writing and confirmed by the employees' signature (Section 14 GefStoffV, Section 14 BioStoffV); for work equipment, the date and names of those instructed must be recorded in writing (Section 12 BetrSichV). These ordinances do not say explicitly whether an electronic confirmation replaces the signature. You are on the safe side if employees sign during the oral part – or if you agree the digital procedure with the competent supervisory authority. A robust digital record contains:

• Name of the person instructed and a personal user account instead of a shared login
• Date and time of completion
• Topic, content and version of the learning module
• Result of the comprehension questions
• Contact person for questions and date of the face-to-face part, where planned

Combining digital and face-to-face instruction

In practice, a combination works well: employees learn general content digitally, while workplace-specific and practical content is covered on site. Here is how to proceed:

1. 1

   Split the content

   Use the risk assessment (Gefährdungsbeurteilung) to decide which topics can be taught digitally – such as emergency organisation, fire safety rules, display screen work or general rules of conduct – and which belong at the workplace, such as machines, hazardous substances or protective equipment.

2. 2

   Make the module company-specific

   Use photos and examples from your own company instead of generic slides, keep the language simple and offer the module in other languages where needed.

3. 3

   Set comprehension questions and a contact person

   Each module ends with questions on the content. Name a person who answers questions promptly, and pick up wrongly answered questions in the face-to-face part.

4. 4

   Practical part on site

   The manager shows escape routes, the assembly point and danger spots, instructs orally based on the operating instructions and has employees demonstrate key tasks.

5. 5

   Document and check effectiveness

   Record both parts, collect signatures where they are required, and observe in the following weeks whether the rules are followed in everyday work.

New employees, young workers and language barriers

New employees know neither the danger spots nor the escape routes – the initial instruction before work starts therefore belongs at the workplace. A digital module can prepare the basics, nothing more. Agency workers are instructed by the hiring company, taking their qualifications and experience into account (Section 12 (2) ArbSchG).

Young workers often lack the experience to recognise hazards. Section 29 JArbSchG requires instruction on the particular hazards and the right behaviour before they first work on machines, at dangerous workplaces or with substances hazardous to health – this works better at the workplace than on a screen. Digital formats can help with language barriers, however: instruction must be given in a form and language employees understand (Section 6 (4) of the Workplaces Ordinance, ArbStättV; Section 14 (2) GefStoffV), and DGUV Rule 100-001 mentions sketches, photos or videos where language alone is not enough.

Checklist: digital safety instruction

• Topics derived from the risk assessment and split into digital and on-site
• Content with pictures and examples from your own company
• Comprehension questions at the end of every module
• Contact person for questions named and available
• Completion during working hours ensured
• Oral instruction on hazardous substances and biological agents on site, with signature
• Exercises for PPE against fatal hazards scheduled
• Record with name, date, content, version and test result
• Works council involved, access to learning data regulated

Free templates for this guide

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

• Safety instruction

  Safety instruction record template (PDF) and instruction plan (Excel)

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• Safety instruction

  New employee safety induction checklist (PDF)

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Frequently asked questions