Agiliton
Sector obligation map

Mandatory training obligations in energy & utilities

14 training duties across 11 instruments binding Energy & Utilities, plus 10 that bind you whatever your sector — statute, rulebook, statutory guidance and licence conditions. Every one traced to its clause, its date and its published source, and each one labelled with what makes it a training duty.

JurisdictionUnited Kingdom
Built2026-08-10
Training duties24
Instruments19
Verified24 of 24
Every entry traced to a published clause

The duties in this sector are drafted around a test or a trigger, almost never around a date.

Section 2(2)(c) of the 1974 Act requires such training “as is necessary”, so far as is reasonably practicable — a proportionality standard judged afterwards, against the risks the employer actually had.

Regulation 13 of the 1999 Regulations is more specific and more demanding: the duty fires on change. And on a COMAH or nuclear site, a further layer applies that reaches beyond the payroll entirely and, in one case, beyond the operator’s own control.

The obligations

Each clause carries a label saying why it is a training duty. Where the instrument does not use the word, we cite the guidance or the case that makes training the way you discharge it. Where we cannot cite anyone, it is not listed as a training duty at all.

says trainThe instrument itself requires training, instruction or CPD.
competenceThe instrument requires competence, qualification or knowledge. Training is the usual means; the instrument does not name it.
guidanceThe binding duty is an outcome. Official guidance under the instrument names training as how it is discharged.
case lawThe binding duty is an outcome. Case law makes training the operative discharge.
ClauseWho must be trained or assessedWhat is requiredIntervalEvidence required
Health and Safety at Work etc. Act 1974
Section 2(2)(c)
says train
all staff — employees, so far as is reasonably practicableThe provision of such information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of the employer's employees. It sits under the general duty in s.2(1) to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all employees.none specified — the test is what "is necessary"none specified in this section
The Management of Health and Safety at Work Regulations 1999
Regulation 13 (Capabilities and training)
says train
all staff — employees, on defined trigger eventsThe employer must take employees' health and safety capabilities into account when entrusting tasks, and must ensure employees are provided with adequate health and safety training on recruitment, and on being exposed to new or increased risks because of a transfer or change of responsibilities, the introduction of or change to work equipment, the introduction of new technology, or the introduction of or change to a system of work. The training must be repeated periodically where appropriate, be adapted to new or changed risks, and take place during working hours.no interval — trigger-based, plus "repeated periodically where appropriate"none specified in this regulation
The Control of Major Accident Hazards Regulations 2015
Schedule 2, paragraph 2(a)(ii), given effect by regulation 7
says train
defined population — personnel at all levels of the organisation involved in the management of major accident hazardsThe safety management system must address the identification of the training needs of such personnel and the provision of the training. It must also establish clear roles and responsibilities for personnel managing major hazards at all levels of the organisation, with measures to promote continuous improvement in awareness.none specifiedThe written major accident prevention policy required by regulation 7, implemented by the safety management system
Schedule 2, paragraph 2(e)(ii)
says train
all staff on site — quoted: "such training to be given to all personnel working in the establishment, including relevant subcontracted personnel"The safety management system must include specific training for staff in relation to planning for emergencies, and that training must be given to all personnel working in the establishment, including relevant subcontracted personnel.none specifiednone specified in this paragraph
ONR nuclear site licence conditions
Licence Condition 10 (Training), paragraphs 1 to 3
says train
defined population — quoted: "all those on site who have responsibility for any operations which may affect safety"The licensee shall make and implement adequate arrangements for suitable training for all those on site who have responsibility for any operations which may affect safety. The licensee shall submit to ONR for approval such part or parts of those arrangements as ONR may specify. Once approved, the licensee shall ensure that no alteration or amendment is made to the approved arrangements unless ONR has approved such alteration or amendment.none specifiedThe arrangements themselves, in a form ONR has approved, plus evidence that no unapproved alteration has been made
Licence Condition 12 (Duly authorised and other suitably qualified and experienced persons), paragraphs 1 to 4
competence
defined population — persons performing any duties which may affect the safety of operations on the site, or any duties assigned by or under the licence conditionsThe licensee shall make and implement adequate arrangements to ensure that ONLY suitably qualified and experienced persons perform any duties which may affect the safety of operations on the site, or any other duties assigned by or under the conditions. The arrangements shall also provide for the appointment, in appropriate cases, of duly authorised persons to control and supervise operations which may affect plant safety. These arrangements are likewise subject to ONR approval and may not be altered without it.none specifiedThe ONR-approved arrangements; in practice, a demonstrable SQEP judgement before deployment
The Electricity at Work Regulations 1989
Regulation 16 (Persons to be competent to prevent danger and injury)
competence
defined population — any person engaged in a work activity where technical knowledge or experience is necessary to prevent danger or injuryNo person shall be engaged in any work activity where technical knowledge or experience is necessary to prevent danger or, where appropriate, injury, unless he possesses such knowledge or experience, or is under such degree of supervision as may be appropriate having regard to the nature of the work.none specified — the test applies at the point of engagement in the activitynone specified in this regulation
The Gas Safety (Installation and Use) Regulations 1998
Regulation 3
competence
any person carrying out work in relation to a gas fitting or gas storage vesselNo person shall carry out any work in relation to a gas fitting or gas storage vessel unless he is competent to do so. In addition, no employer shall allow an employee to carry out work in relation to a gas fitting or service pipework, and no self-employed person shall carry out such work, unless the employer or self-employed person is a member of a class of persons approved for the time being by the Health and Safety Executive.none specified — competence required at the point of doing the workMembership of the HSE-approved class
The Pressure Systems Safety Regulations 2000
Regulation 11
says train
persons operating the systemThe user or owner must provide adequate and suitable instructions for the safe operation of the system and for action to be taken in the event of an emergency, and must ensure the system is operated only in accordance with those instructions.none specifiedThe instructions themselves
Regulation 8 (Written scheme of examination)
competence
named role — the competent person who draws up, certifies and reviews the written scheme of examinationThe user or owner must ensure a suitable written scheme of examination exists for the protective devices, pressure vessels and pipework concerned. No person shall draw up or certify a scheme unless the scheme is suitable, and the content must be reviewed at appropriate intervals BY A COMPETENT PERSON to determine whether it remains suitable in current conditions of use. The scheme must specify the nature and frequency of examination, necessary preparatory measures, and any pre-use examination requirements.review at appropriate intervals — no interval statedThe written scheme of examination itself
The Provision and Use of Work Equipment Regulations 1998
Regulation 9 (Training)
says train
all persons who USE work equipment, and any employees who SUPERVISE OR MANAGE its useEvery employer shall ensure that all persons who use work equipment have received adequate training for purposes of health and safety, including training in the methods which may be adopted when using the work equipment, any risks which such use may entail and precautions to be taken. The same duty applies to any employees who supervise or manage the use of work equipment.none specifiednone specified in this regulation
Directive (EU) 2022/2555 on measures for a high common level of cybersecurity across the Union (NIS2)
Article 20(2), with Article 20(1)
says train
named population — MEMBERS OF THE MANAGEMENT BODY, required; employees, encouragedMember States shall ensure that the members of the management bodies of essential and important entities ARE REQUIRED TO FOLLOW TRAINING, and shall encourage those entities to offer similar training to their employees ON A REGULAR BASIS, in order that they gain sufficient knowledge and skills to enable them to identify risks and assess cybersecurity risk-management practices and their impact on the services provided. Article 20(1) makes management bodies approve the cybersecurity risk-management measures, oversee implementation, and liable for infringements.employees: "on a regular basis"; management body: no interval statednone specified in this Article
Directive 2012/18/EU on the control of major-accident hazards involving dangerous substances (Seveso III)
Annex III, point (b)(i), given effect by Article 8
says train
defined population — personnel involved in the management of major hazards at all levels, plus employees and SUBCONTRACTED PERSONNEL working in the establishment who are important from the point of view of safetyThe safety management system must address organisation and personnel: the roles and responsibilities of personnel involved in the management of major hazards at all levels in the organisation, together with the measures taken to raise awareness of the need for continuous improvement; the identification of training needs of such personnel and the provision of the training so identified; and the involvement of employees and of subcontracted personnel working in the establishment which are important from the point of view of safety.none specifiedThe major-accident prevention policy and the safety management system implementing it
HSE Approved Code of Practice and guidance L22 — Safe use of work equipment (Provision and Use of Work Equipment Regulations 1998)
ACOP L22, guidance paragraphs 121 to 126 on regulation 9
says train
all persons who USE work equipment, all employees who SUPERVISE OR MANAGE its use, and expressly TEMPORARY WORKERS SUPPLIED BY AN EMPLOYMENT AGENCY (¶121(a)) and YOUNG PEOPLE (¶125)What constitutes adequate training varies by job, activity and equipment. The employer must EVALUATE the existing competence of employees and of others such as agency temporary workers across the full range of equipment they will use; evaluate the competence needed to manage or supervise its use; and train to make up any shortfall (¶121). Circumstances must be taken into account, such as whether the person works alone or under close supervision of a competent person (¶122). Training needs are greatest on recruitment, but training is also required if risks change due to a change in working tasks, if new technology or equipment is introduced, or if the system of work changes (¶123). Refresher training must be provided when necessary, because skills decline if not used regularly — checks are expected after a lengthy absence, or when a worker moves to a process that has changed since they last performed it (¶124). Induction training is particularly important for young people given their relative immaturity and unfamiliarity with the working environment (¶125).no fixed interval — refresher training "when necessary", driven by skill decay, absence and changeThe competence evaluation and the identified shortfall — the ACOP frames the duty as an assessment followed by targeted training, not as delivery

Binds you whatever your sector

10 further obligations sit outside Energy & Utilities regulation and bind you as an employer or as a deployer of AI. They are the ones a sector-by-sector review misses, because nobody who reads only their own rulebook ever reaches them.

ClauseWho must be trained or assessedWhat is requiredIntervalEvidence required
EU AI Act (Reg (EU) 2024/1689)
Article 4 (AI literacy)
says train
defined population — quoted from the pre-amendment text: "their staff and other persons dealing with the operation and use of AI systems on their behalf"AS ENACTED: providers and deployers were to take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account technical knowledge, experience, education and training, the context of use, and the persons on whom the systems are used. AS AMENDED from 2026-07-27 by the Digital Omnibus on AI: AI literacy remains an obligation on providers and deployers, but no specific or 'sufficient' level is mandated; the Commission and Member States take a stronger role in promoting AI literacy. The obligation on deployers of HIGH-RISK AI systems to ensure staff are trained for human oversight remains in place.none specifiednone specified
Article 26(2)
says train
named population — the natural persons assigned to exercise human oversightQuoted: "Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support."none specifiednone specified in this paragraph
Employment Rights Act 2025
Whole Act — training provisions at s.65 and related
says train
named role — trade union equality representatives, not the general workforceThe Act's training provisions concern whether a trade union equality representative has undergone sufficient training to carry on those activities, with notice requirements on the union and reference to a relevant ACAS or Secretary of State Code of Practice. It is not a mandatory workforce training duty of the kind the rest of this map records.none specifiedWritten notice from the trade union to the employer
Equality Act 2010
Section 109(4), with section 109(1)
case law
Allay (UK) Ltd v Gehlen [2021] UKEAT/0031/20 — stale or inadequate training defeats the s.109(4) 'all reasonable steps' defence, making training the operative discharge.
all staff — the defence turns on steps taken to prevent employees doing discriminatory actsAn employer is liable for anything done by a person in the course of their employment. Quoted from 109(4): "In proceedings against A's employer (B) in respect of anything alleged to have been done by A in the course of A's employment it is a defence for B to show that B took all reasonable steps to prevent A—(a) from doing that thing, or (b) from doing anything of that description."none specifiedThe employer must SHOW the steps taken. The burden sits with the employer.
UK GDPR
Article 24, read with Article 5(2)
guidance
UK GDPR Article 39(1)(b) — read at source 2026-08-12 — names staff training as an element of compliance with the Regulation: the data protection officer must "monitor compliance with this Regulation... including the assignment of responsibilities, awareness-raising and training of staff involved in processing operations, and the related audits". LIMIT OF THIS CITATION, stated plainly: Article 39 applies only where Article 37 requires a DPO to be appointed, so it does not by itself establish a training duty for every controller. It establishes that the Regulation treats staff training as part of compliance. The unconditional citation would be the ICO Accountability Framework, which has NOT been read — see not_yet_searched.
not specified — training is not expressly named in Article 24Quoted: "the controller shall implement appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is performed in accordance with this Regulation." Those measures must be reviewed and updated where necessary, and are to include appropriate data protection policies where proportionate to the processing activities. Article 5(2) supplies the accountability principle itself: "The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1" — that is, with all six data protection principles: lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; and integrity and confidentiality.measures to be reviewed and updated where necessary — no intervalThe controller must be able to DEMONSTRATE compliance. This is the accountability limb.
The Regulatory Reform (Fire Safety) Order 2005
Article 21, with articles 3 and 6
says train
all staff — quoted: "his employees"Quoted, 21(1): the responsible person "must ensure that his employees are provided with adequate safety training (a) at the time when they are first employed; and (b) on their being exposed to new or increased risks because of" transfer or change of responsibilities, new or changed work equipment, new technology, or a new or changed system of work. 21(2): that training must "(a) include suitable and sufficient instruction and training on the appropriate precautions and actions to be taken by the employee in order to safeguard himself and other relevant persons on the premises; (b) be repeated periodically where appropriate; (c) be adapted to take account of any new or changed risks; (d) be provided in a manner appropriate to the risk identified by the risk assessment; and (e) TAKE PLACE DURING WORKING HOURS."Trigger-based, not periodic: on first employment AND on each of four listed changes. "Repeated periodically where appropriate" — no interval stated.none specified in the article
The Management of Health and Safety at Work Regulations 1999
Regulation 13(2), with 13(1) and 13(3)
says train
all staff — every employee, on recruitment and again on each triggering changeQuoted, 13(2): "Every employer shall ensure that his employees are provided with adequate health and safety training— (a) on their being recruited into the employer's undertaking; and (b) on their being exposed to new or increased risks because of— (i) their being transferred or given a change of responsibilities within the employer's undertaking, (ii) the introduction of new work equipment into or a change respecting work equipment already in use within the employer's undertaking, (iii) the introduction of new technology into the employer's undertaking, or (iv) the introduction of a new system of work into or a change respecting a system of work already in use within the employer's undertaking." 13(1) separately requires the employer, "in entrusting tasks to his employees, [to] take into account their capabilities as regards health and safety."No fixed interval. The duty is TRIGGER-BASED — on recruitment, and on each of the four changes listed in 13(2)(b).Not specified in the regulation itself.
Health and Safety at Work etc. Act 1974
Section 2(2)(c), with section 2(1)
says train
all staff — scoped by what is 'necessary to ensure' their health and safetyQuoted, s.2(2)(c): the employer's general duty extends in particular to "the provision of such information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of his employees." This is the primary-legislation parent of the MHSWR reg 13 duty. Note the double qualifier: training is owed only so far as it is BOTH 'necessary to ensure' health and safety AND 'reasonably practicable'.None. The measure is necessity, not interval.Not specified in the section.
Council Directive 89/391/EEC (the Framework Directive) on the introduction of measures to encourage improvements in the safety and health of workers at work
Article 12(1) and 12(4)
says train
all staff — 'each worker'Quoted, 12(1): "The employer shall ensure that each worker receives adequate safety and health training, in particular in the form of information and instructions specific to his workstation or job: — on recruitment, — in the event of a transfer or a change of job, — in the event of the introduction of new work equipment or a change in equipment, — in the event of the introduction of any new technology. The training shall be: — adapted to take account of new or changed risks, and — repeated periodically if necessary." Quoted, 12(4): "The training referred to in paragraphs 1 and 3 MAY NOT BE AT THE WORKERS' EXPENSE... The training referred to in paragraph 1 MUST TAKE PLACE DURING WORKING HOURS."No fixed interval. Trigger-based on four named events, PLUS two standing qualities the UK implementation does not spell out as clearly: adapted to new or changed risks, and "repeated periodically if necessary".Not specified in Article 12.
Article 12(2)
says train
named population — workers from OUTSIDE undertakings and/or establishments engaged in work in your undertaking. Contractors, agency staff, visiting engineers, maintenance crews.Quoted in full: "The employer shall ensure that workers from outside undertakings and/or establishments engaged in work in his undertaking and/or establishment HAVE IN FACT RECEIVED appropriate instructions regarding health and safety risks during their activities in his undertaking and/or establishment."None — triggered by the outside workers being engaged in work in your undertaking.Not specified, but note the wording: the employer must ensure they "have in fact received" the instructions. That is a verification duty, not a provision duty — it is not discharged by having issued something.

Related duties — not training obligations

2 provisions that sit alongside the duties above without themselves requiring training. They are here because they are the ones most often mistaken for training duties, or most often missed when scoping them. We separate them rather than pad the count.

ClauseWho it concernsWhat is requiredIntervalEvidence required
The Control of Major Accident Hazards Regulations 2015
Schedule 2, paragraph 2(a)(iii)
related
Quoted limb is participation of personnel, not training. COMAH Sch 2 para 2(a)(i)-(ii) may carry the training limb and are UNREAD — see not_yet_searched.
defined population — employees AND SUBCONTRACTORS whose work affects safetyThe safety management system must ensure the participation of employees and of subcontracted personnel whose work is important from the point of view of safety.none specifiednone specified in this paragraph
ONR nuclear site licence conditions
Licence Condition 36 (Organisational capability), paragraphs 1 to 4
related
Record itself declares this is not a training duty.
n/a — a capability and change-control duty over human resourcesThe licensee shall provide and maintain adequate financial and HUMAN RESOURCES to ensure the safe operation of the licensed site. Without prejudice to that, the licensee shall make and implement adequate arrangements to control any change to its organisational structure or resources which may affect safety. Those arrangements are subject to ONR approval and, once approved, may not be altered without ONR's approval.none specified — continuous, with change as the triggerONR-approved arrangements for controlling organisational change

Where gaps commonly sit

The training arrangements are not yours to change

Nuclear Licence Condition 10 is the most constrained training obligation in this series. The licensee must make and implement adequate arrangements for suitable training for all those on site with responsibility for operations that may affect safety — then submit those arrangements to ONR for approval.

Once approved, no alteration or amendment may be made unless ONR has approved it. A well-intentioned improvement made unilaterally is itself a breach.

Licence Condition 12 works as its pair: only suitably qualified and experienced persons may perform duties affecting safety. LC10 asks whether the arrangements are adequate and approved; LC12 asks whether the person on the plant today was judged SQEP before deployment.

The duty fires on change, not on a date

Regulation 13(2) lists its triggers: recruitment, transfer or change of responsibilities, new or changed work equipment, new technology, and new or changed systems of work. Regulation 13(3) then requires the training to be repeated periodically where appropriate, adapted to take account of any new or changed risks, and to take place during working hours.

A fixed annual refresh is a schedule. It will be late for every change occurring the week after it runs, and content not adapted to that change cannot have been adapted to it.

The population is defined by site presence, not employment

COMAH Schedule 2 draws the widest population in this map. Paragraph 2(a)(iii) requires the participation of employees and subcontracted personnel whose work is important for safety. Paragraph 2(e)(ii) goes further on emergency preparedness: such training is “to be given to all personnel working in the establishment, including relevant subcontracted personnel”.

That is a presence test, not an employment test — so it captures contractors, visiting engineers and long-term agency staff, who are precisely the people absent from the system an operator would reach for to evidence it.

Competence, or supervision — and two gates where one is assumed

Regulation 16 of the Electricity at Work Regulations offers a genuine alternative to competence: appropriate supervision, having regard to the nature of the work. What must be evidenced is the judgement about which route applies to this person on this activity.

Regulation 3 of the Gas Safety (Installation and Use) Regulations sets two separate gates that are routinely collapsed into one. Individual competence is the first. Membership of an HSE-approved class is the second, and it attaches to the employer, not the engineer.

Coverage

This map states what it did not check as well as what it did. A map that quietly omits its own gaps is worth less than one that marks them.

Searched and found

14 obligations across 11 instruments, each read directly from the published source on 2026-08-10.

Searched and found nothing

Recorded because “we searched and found nothing” is a different fact from “we did not search”.

  • The Network and Information Systems Regulations 2018 — Staff training or awareness is NOT expressly required by regulation 10. The duty is to take appropriate and proportionate technical and organisational measures to manage risk, prevent and minimise incidents, and to have regard to guidance issued by the relevant competent authority.
Not searched

Their absence is not evidence that they contain no training duty.

  • ONR Safety Assessment Principles and Technical Assessment Guides
  • Gas Safety (Management) Regulations 1996
  • Pressure Systems Safety Regulations 2000 regulation 9 and the remaining provisions
  • Competent-authority guidance issued under NIS 2018 reg 10(4)
  • National transpositions of NIS2 and Seveso III for the non-UK pool
  • HSE ACOPs L112 (power presses), L114 (woodworking machinery) and L117 (rider-operated lift trucks) — L22 read, these three remain

Sources

Thirty minutes, on your own material

Ten minutes on where your obligations actually sit. Fifteen watching a module built live from your own source documents. Five on whether there is a next step. Nothing to prepare and nothing to send beforehand.

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