AGG training for managers and employees

How it runs

1. 1

   Scoping

   We settle headcount, how many of those carry personnel responsibility, which languages the workforce needs and what material already exists, including any group-level course. We also ask whether a complaints body under Section 13 AGG has been named, because without a named reporting route the training loses its most important chapter. The output is the cut of the two tracks and the choice of format.

2. 2

   Content

   The statutory part is identical in both tracks and follows Sections 1, 3, 7 and 12 AGG. The company-specific part is not: the reporting route, the named contacts, the applicable works agreement and your escalation path appear by name in the materials. You approve the content before rollout.

3. 3

   Rollout inside the company

   The workforce is told that training is happening, why, by when and what happens to the participation data. This step also checks that the publication required by Section 12 Para. 5 AGG is in place, meaning the Act, Section 61b ArbGG and the information about the competent complaints body. Training that arrives at a company with no such notice leaves a gap, and it is the first thing an inspection looks for.

4. 4

   Delivery

   The e-learning goes live with a deadline and reminders, the live workshops run to schedule, and the manager track runs separately from the core track. Attendance and completion are recorded per person while delivery is running, rather than reconstructed afterwards.

5. 5

   Evidence and adjustment

   You receive the evidence position per person and as an export. Then comes the part a pure e-learning vendor structurally cannot offer: anonymised complaint patterns from the complaints body show where the training did not hold, and those points go into the next version of the content. Where CIVAC also runs the external complaints body under Section 13 AGG, that loop runs without a separate hand-off. It is also the running evidence for the preventive measures required by Section 12 Para. 1 AGG.

The legal frame

The following provisions determine what training has to achieve, what it is about and what it does. Each is quoted in the German original, because that is the wording that binds, with the effect stated underneath.

Section 12 Para. 2 AGG

Der Arbeitgeber soll in geeigneter Art und Weise, insbesondere im Rahmen der beruflichen Aus- und Fortbildung, auf die Unzulässigkeit solcher Benachteiligungen hinweisen und darauf hinwirken, dass diese unterbleiben. Hat der Arbeitgeber seine Beschäftigten in geeigneter Weise zum Zwecke der Verhinderung von Benachteiligung geschult, gilt dies als Erfüllung seiner Pflichten nach Absatz 1.

The only place in the AGG that attaches a legal consequence to having trained. Sentence 1 names vocational training as the route; sentence 2 provides that suitable training counts as fulfilment of the duties under Para. 1. Both sentences turn on suitability rather than on duration or format, and suitability has to be capable of proof in a dispute.

Section 12 Para. 1 AGG

Der Arbeitgeber ist verpflichtet, die erforderlichen Maßnahmen zum Schutz vor Benachteiligungen wegen eines in § 1 genannten Grundes zu treffen. Dieser Schutz umfasst auch vorbeugende Maßnahmen.

The base duty that Section 12 Para. 2 sentence 2 AGG refers back to. Its second sentence makes clear that protection does not begin after an incident: it includes preventive measures. Training is the preventive measure the Act itself names.

Section 3 Para. 3 and Para. 4 AGG

Eine Belästigung ist eine Benachteiligung, wenn unerwünschte Verhaltensweisen, die mit einem in § 1 genannten Grund in Zusammenhang stehen, bezwecken oder bewirken, dass die Würde der betreffenden Person verletzt und ein von Einschüchterungen, Anfeindungen, Erniedrigungen, Entwürdigungen oder Beleidigungen gekennzeichnetes Umfeld geschaffen wird. Eine sexuelle Belästigung ist eine Benachteiligung in Bezug auf § 2 Abs. 1 Nr. 1 bis 4, wenn ein unerwünschtes, sexuell bestimmtes Verhalten, wozu auch unerwünschte sexuelle Handlungen und Aufforderungen zu diesen, sexuell bestimmte körperliche Berührungen, Bemerkungen sexuellen Inhalts sowie unerwünschtes Zeigen und sichtbares Anbringen von pornographischen Darstellungen gehören, bezweckt oder bewirkt, dass die Würde der betreffenden Person verletzt wird, insbesondere wenn ein von Einschüchterungen, Anfeindungen, Erniedrigungen, Entwürdigungen oder Beleidigungen gekennzeichnetes Umfeld geschaffen wird.

The substantive core of the training. Both paragraphs turn on what conduct brings about, not only on what it was meant to achieve, and Para. 4 lists concrete conduct rather than leaving it to interpretation. Once a workforce has read this, the argument about a remark stops being an argument about how it was intended.

Section 12 Para. 3 and Para. 4 AGG

Verstoßen Beschäftigte gegen das Benachteiligungsverbot des § 7 Abs. 1, so hat der Arbeitgeber die im Einzelfall geeigneten, erforderlichen und angemessenen Maßnahmen zur Unterbindung der Benachteiligung wie Abmahnung, Umsetzung, Versetzung oder Kündigung zu ergreifen. Werden Beschäftigte bei der Ausübung ihrer Tätigkeit durch Dritte nach § 7 Abs. 1 benachteiligt, so hat der Arbeitgeber die im Einzelfall geeigneten, erforderlichen und angemessenen Maßnahmen zum Schutz der Beschäftigten zu ergreifen.

The reason the manager track is separate. The duty falls on the employer, but in practice it is triggered where the complaint first lands, and that is rarely the complaints body. Para. 4 extends it to disadvantage by third parties, meaning customers, audiences and contractors' staff, and those are the cases missing from most internal policies.

Quoted as the law stood on 12 August 2026. An amendment procedure on the AGG is under way which affects, among other things, the deadline in Section 15 Para. 4 AGG. The wording in force at the time governs, not this page.

How the price is built

The price has four components, each shown separately. That makes the offer comparable with others even where they are cut differently.

• Headcount, and how many of those carry personnel responsibility.
• Number of language versions the workforce needs.
• E-learning, live workshop or a mix of both.
• Number of live sessions and whether they run on site or online.
• Whether the manager track runs as its own session or is folded into the core track.

You receive a fixed figure per component once headcount, format and languages are settled. The platform is EUR 49 per officer role per month and is shown separately in the offer.

Frequently asked

Is AGG training mandatory in Germany?

The AGG contains no free-standing training obligation with a prescribed scope, but it comes very close. Section 12 Para. 1 AGG obliges the employer to take the necessary measures to protect against discrimination and states that this protection includes preventive measures. Section 12 Para. 2 sentence 1 AGG then names vocational training expressly as the route, phrased as a should-provision. Sentence 2 of the same paragraph attaches a consequence: suitable training counts as fulfilment of the duties under Para. 1. In practice that means the employer must act, the statute names training as the way to act, and an employer who takes that route has express statutory recognition for it. An employer choosing a different route has to be able to show that the measures taken were necessary and suitable.

How often does AGG training have to be repeated?

The AGG names no interval. Neither Section 12 AGG nor any other provision of the Act prescribes a cycle, and anyone asserting a legally required annual AGG training should be asked for the citation. For comparison, even Section 12 Para. 1 ArbSchG, which governs health and safety instruction, names occasions rather than a number: on hiring, on changes to the field of work, and repetition at regular intervals where necessary. The workable approach is therefore trigger-based rather than calendar-based: on joining, on moving into a role with personnel responsibility, when the reporting route or the works agreement changes, and when complaint patterns show that a topic has not landed. Many companies additionally fix a cycle of their own so the evidence position does not age. That is a company decision, not a statutory requirement.

Why do managers need training separate from the rest of the workforce?

Because they hold a different position in the procedure. Employees need to recognise what constitutes disadvantage under Section 3 AGG and where to turn under Section 13 Para. 1 AGG. Managers need to know in addition what to do when a complaint arrives with them, and in practice it arrives with them before it reaches the complaints body. The duty to take measures under Section 12 Para. 3 AGG falls on the employer, but the manager's reaction is the point at which it is decided whether the company acts at all. On top of that come duties that only managers carry: discrimination-free selection and appraisal, the duty to protect against disadvantage by third parties under Section 12 Para. 4 AGG, and the prohibition of victimisation in Section 16 AGG, which bars detriment for having raised a complaint.

Does the training cover bullying, or only discrimination under the AGG?

Both, but kept apart, because the law keeps them apart. The AGG catches harassment under Section 3 Para. 3 AGG only where the unwanted conduct is connected to one of the grounds listed in Section 1 AGG, namely race or ethnic origin, gender, religion or belief, disability, age or sexual identity. Bullying without such a connection falls outside the AGG, though it remains relevant under general employment law and the employer's duty of care, and for the person affected it is the same problem. The training therefore covers both and marks the boundary, because a workforce uses the same words for different situations. For the manager track the distinction matters most, since it determines which procedure applies and which deadlines start to run.

Is e-learning enough, or does the training have to be in person?

Section 12 Para. 2 AGG prescribes no format. It requires the employer to point out in a suitable manner that discrimination is not permitted and gives vocational training as the example, without distinguishing between digital and in-person delivery. The test is suitability, which turns on the content, on reaching the whole workforce and on whether participation can be shown afterwards. In practice e-learning with a final test carries the core track well, because it reaches every individual and produces a record per person. For managers a live format is preferable, because that is where questions about concrete situations arise, which a test does not catch. That is why mixed delivery is the form most often chosen.

How is participation in AGG training evidenced?

Through a record per person, not a completion rate per department. What is captured is the date, the format, the version of the content and the completion, plus the result of the final test for e-learning and attendance at the specific session for a live workshop. Every participant receives a certificate of participation, and open or overdue participation is chased automatically. The full position is available as an export for group internal audit, external auditors or for the case where the training has to be shown in a dispute. This is where offers differ most: content is plentiful, whereas a per-person record that still shows years later who completed what and when is the part that is needed when it matters.

Does AGG training protect against claims under Section 15 AGG?

Not automatically, and no provider should promise that it does. What the statute says is Section 12 Para. 2 sentence 2 AGG: where the employer has trained employees in a suitable manner for the purpose of preventing discrimination, this counts as fulfilment of the employer's duties under Para. 1. That is a statement about the duties in Section 12 Para. 1 AGG, not a statement about how an individual claim is decided. Section 22 AGG also remains untouched: a party who proves indicia suggesting discrimination shifts the burden of proof to the other side, and training does not change that. Whether training counts as suitable in a given case, and what follows from it, is for the courts to judge. CIVAC provides the delivery and the evidence and does not assess an individual case.