Online safety instruction is allowed in Germany, but only as an aid. The statutory accident insurers' umbrella body, DGUV, puts it plainly in its guidance paper FBORG-004: instruction can be delivered with electronic media as long as employees can ask questions out loud and someone checks that they understood. Sending a course link and watching the completion rate is not instruction under German rules.
That covers e-learning, video calls and VR headsets alike. This guide explains what § 12 of the Occupational Safety and Health Act (ArbSchG) and DGUV Regulation 1 require, where DGUV draws the line for electronic formats, and what a process looks like that would survive an inspection. In German this duty is called Unterweisung; we use "instruction" below.
What § 12 ArbSchG and DGUV Regulation 1 require
The employer must instruct employees adequately and appropriately during working hours, with directions and explanations aimed specifically at their workplace or tasks. DGUV Regulation 1 adds that instruction must be repeated at least once a year and documented. Neither text prescribes a medium.
The wording is in § 12 ArbSchG (gesetze-im-internet.de, in German). Instruction is due on hiring, on a change of tasks, and when new equipment or technology arrives, each time before the person starts the work. For agency workers the duty sits with the hiring company.
§ 4 of DGUV Regulation 1 with the DGUV Rule 100-001 commentary (BGHM, in German) sets the yearly minimum. Other rules can be stricter: young workers must be instructed every six months under § 29 of the Youth Employment Protection Act. Our free Unterweisung Arbeitsschutz for Germany reference tool (in German) lists which triggers and intervals apply to which activity, with a source for each.
On format, Rule 100-001 is the text to read. Instruction must be given in an understandable form and language. Whoever is responsible must make sure people understood it, and employees must be able to ask questions. The commentary draws the conclusion itself: handing over material for self-study alone is not enough.
What DGUV says about electronic media
DGUV accepts electronic instruction when it comes with the option of additional spoken explanation, one to one or in a group, for example over a video or phone call. Two conditions always apply: there has to be a comprehension check, and the people being instructed must be able to ask questions verbally.
That is section 3.5 of FBORG-004 "Instruction in the home office" (DGUV, 2021, in German). The paper was written for remote work, but its statements on electronic media are general. It names one setup as explicitly insufficient: working through instruction software on its own, with no spoken contact and no way to ask.
How do you check understanding? FBORG-004 offers three ways: ask questions, have the person demonstrate or describe the procedure, or hold a conversation between instructor and employee. A quiz at the end of a module can be part of that. It does not replace the conversation.
Rule 100-001 adds one more point. When electronic aids are used, some procedures and behaviours may also need to be taught in practice. And it is the supervisors who check whether the instruction worked.
Where electronic formats fall short
German instruction is tied to the specific workplace, while electronic media tend to be more general. DGUV names cases where they are not enough on their own: complex hazard situations, work on machines, and putting on and using respirators and other personal protective equipment correctly.
The DGUV page on electronically supported instruction (DGUV, in German) also lists the benefits: learners can be anywhere, mobile staff can be reached, and content can be multimedia and multilingual. Practical procedures, though, must "still be practised concretely".
Site-specific questions rarely generalise. Where is the assembly point for hall 3? Who isolates the line before maintenance? Someone who knows the site has to answer those.
Documentation and signatures
DGUV Regulation 1 requires instruction to be documented but prescribes no format and no signature. Some state regulations do demand written records or a signature. For evidence purposes, DGUV still recommends recording every instruction in writing.
For electronic signatures, section 3.8 of FBORG-004 separates three cases. A pasted image of a signature is not clear proof. A scanned, hand-signed document is better. If the signature is meant to hold up legally, DGUV points to the qualified electronic signature (QES).
In practice, the record should show the date, the topic, the instructor and the participants. A learning system that stores completions with a date and a result covers that part automatically. The spoken part still needs to be written down.
Certified instruction software
Certification is not mandatory. The accident insurers do recommend tested products, and the IAG certification body within DGUV Test certifies electronic instruction aids voluntarily, against its own test principles.
Section 3.6 of FBORG-004 summarises what those principles demand. The product comes with documentation so instructors can judge what it can and cannot do. That documentation clearly states the duty to add spoken instruction. The program itself says so at least at the start and the end of each module.
So even a certified program does not discharge the duty by itself. The certificate confirms that it asks for the spoken part.
Where VR fits into German instruction
VR is an electronic aid and follows the same rules. Its advantage sits exactly where classic e-learning is weak: practice. Dangerous situations can be rehearsed without risk, and the instruction gains the hands-on element that Rule 100-001 asks for when electronic aids are used.
The German Institute for Occupational Safety and Health of the DGUV (IFA) has tested this approach. At Airbus, the use of fall protection was explained in the annual safety instruction, mostly through a slide presentation. Together with the accident insurer BG ETEM, IFA built a VR course set on a virtual workstation on an aircraft wing, to add practical elements to the slides (IFA project sheet no. 0416, 2020, in German). First tests showed that users had respect for the virtual height. IFA also names the limits: no sense of touch, and for some people dizziness and discomfort, known as VR sickness.
A workable sequence looks like this. The supervisor opens the session and explains what is specific to the site. Employees practise in the headset, for example working at height or spotting workplace hazards. Questions and a short conversation follow as the comprehension check. The VR LMS records who completed which scenario, when, and with what result.
How our scenarios map onto German duties is explained on our page about VR safety training in Germany (in German).
Checklist for online safety instruction in Germany
- The risk assessment states which content is taught electronically and which on site in practice.
- Every electronic unit has a named contact for questions, live or by video.
- Understanding is checked through questions, a demonstration or a conversation, and a "read" button alone does not count.
- Site-specific points such as the assembly point, emergency numbers and isolation are explained by someone who knows the workplace.
- The record shows the date, topic, instructor and participants, including the spoken part.
- The yearly deadline runs from the date of the last instruction.
For the events that trigger instruction on top of the yearly cycle, read when to repeat safety instruction in Germany. For a comparison with a neighbouring system, see UK health and safety training requirements. All scenarios are in our VR training catalog.
