2 training duties across 1 instrument binding Telecoms, 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.
One regulation, headed “Competency”, containing three different populations — and one of them does not work for you.
Telecoms carries few named training duties, and they sit almost entirely in the security regime built on section 105A of the Communications Act 2003. What that regime asks for is competence plus resources, which is an unusual pairing: a competent person who has not been given the means to act is expressly not enough.
We searched the whole of the Communications Act 2003 — 2.6 million characters — and the whole of the 2022 Security Measures Regulations. What is below is what those instruments name. The guidance layer that says how the duties are met, Ofcom’s Telecommunications Security Code of Practice, is declared unread.
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.
| Clause | Who must be trained or assessed | What is required | Interval | Evidence required |
|---|---|---|---|---|
| The Electronic Communications (Security Measures) Regulations 2022 | ||||
| Regulation 13(1), 13(2)(a) and 13(2)(d)(i) competence | named role — the 'responsible persons', i.e. persons given responsibility for taking security measures on behalf of the provider; and separately, the security personnel who approve equipment configuration | The regulation is headed "Competency". Quoted, 13(1): the provider "must take such measures as are appropriate and proportionate to ensure that persons given responsibility for the taking of measures on behalf of the provider... ('the responsible persons')— (a) are competent to discharge that responsibility, and (b) are given resources to enable them to do so." 13(2)(a) makes that duty include "a duty to take such measures as are appropriate and proportionate— (a) to ensure that the responsible persons have appropriate knowledge and skills to perform their responsibilities effectively". And 13(2)(d)(i) requires that where new equipment is supplied by a third party, it "is set up according to a secure configuration approved by APPROPRIATELY TRAINED SECURITY PERSONNEL, following procedures which enable it to be demonstrated that the configuration has been carried out in that way". | None. The duty is qualified throughout by 'appropriate and proportionate'. | 13(2)(d)(i) requires procedures "which enable it to be demonstrated that the configuration has been carried out in that way" — a demonstrability requirement attached to the trained-personnel limb. |
| Regulation 14(4)(a), with 14(1), 14(2) and 14(3) competence | named population — 'persons involved in the provision of the network or service', whose competence and skills are themselves an object of the testing | Quoted, 14(1): the provider "must at appropriate intervals carry out, or arrange for a suitable person to carry out, such tests in relation to the network or service as are appropriate and proportionate for the purpose of identifying the risks of security compromises". 14(2): "The tests must involve simulating, so far as is possible, techniques that might be expected to be used by a person seeking to cause a security compromise." 14(4): "The references to tests in relation to the network or service INCLUDE references to tests in relation to— (a) THE COMPETENCE AND SKILLS OF PERSONS INVOLVED IN THE PROVISION OF THE NETWORK OR SERVICE, and (b) the possibility of unauthorised access to places where the ... provider keeps equipment". And 14(3) requires the provider to ensure, so far as reasonably practicable, that the manner of the tests is not made known to those persons and "that measures are taken to prevent any of the persons mentioned in sub-paragraph (a) being able to ANTICIPATE THE TESTS to be carried out." | "At appropriate intervals" — no fixed period, but expressly recurring rather than one-off. | Not specified in reg 14, but the testing is itself the evidence — this is a duty to generate proof of competence rather than to record delivery. |
10 further obligations sit outside Telecoms 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.
| Clause | Who must be trained or assessed | What is required | Interval | Evidence 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 specified | none specified |
| Article 26(2) says train | named population — the natural persons assigned to exercise human oversight | Quoted: "Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support." | none specified | none 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 workforce | The 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 specified | Written 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 acts | An 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 specified | The 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 24 | Quoted: "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 interval | The 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 change | Quoted, 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 safety | Quoted, 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. |
Regulation 13(1) of the Electronic Communications (Security Measures) Regulations 2022 requires that the responsible persons “(a) are competent to discharge that responsibility, and (b) are given resources to enable them to do so.”
The second limb is unusual in UK training law and it is the one that fails in practice. A well-trained security lead with no budget and no headcount does not satisfy regulation 13.
Regulation 13(2)(c) requires the responsible persons to be competent “to show appropriate understanding and appraisal of the activities of third party suppliers and of any recommendations made by third party suppliers for the purposes of identifying and reducing the risk of security compromises”.
That is a procurement and vendor-assurance skill, not a network-security one, and it rarely appears in a security curriculum built around the estate you own.
Regulation 13(2)(d)(i) requires new third-party equipment to be “set up according to a secure configuration approved by appropriately trained security personnel, following procedures which enable it to be demonstrated that the configuration has been carried out in that way”.
Two things follow. The approver is often a vendor engineer rather than an employee — so the training duty reaches outside the payroll. And the demonstrability requirement means the evidence has to exist at configuration time, not be reconstructed afterwards.
Regulation 14 requires security testing “at appropriate intervals” that simulates “techniques that might be expected to be used by a person seeking to cause a security compromise”. Then 14(4) says what is in scope:
“The references to tests… include references to tests in relation to (a) the competence and skills of persons involved in the provision of the network or service.”
And 14(3) makes it unannounced — the provider must ensure the manner of the tests is not made known to those people, and that “measures are taken to prevent… being able to anticipate the tests”.
A completion report is not responsive to this. Regulation 14 asks whether your people are actually competent, and it asks by testing them without warning. Only one other duty in this series works that way — the Gambling Commission’s test purchasing.
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.
2 obligations across 1 instruments, each read directly from the published source on 2026-08-12.
Their absence is not evidence that they contain no training duty.
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.