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Universities in NRW: KI-VO and their new obligations revealed!
New report on the KI-VO: Obligations for universities in NRW published, relevant measures and exceptions explained.
Universities in NRW: KI-VO and their new obligations revealed!
On August 26, 2025, a new legal opinion was published by the research project KI:edu.nrw, which deals with the obligations of universities regarding artificial intelligence (AI). This report offers a comprehensive classification of the EU AI Regulation (KI-VO) and its effects on educational institutions. The central question of whether the KI-VO applies to universities is examined and answered clearly: in most cases yes, although there are exceptions.
According to the report, universities do not have to comply with the AI Regulation if they develop AI systems exclusively for research purposes. However, as soon as a practical use or a possible later practical use is considered, the AI Regulation applies from the moment an AI system is put into operation. This represents an important legal nuance that impacts the planning and implementation of AI projects in universities.
Commitments and high-risk AI
Universities are obliged to take measures to ensure AI competence. This creates obligations both as providers and as operators in accordance with the KI-VO. Particularly relevant requirements apply to so-called high-risk AI systems, for example those used to assess learning outcomes. This classification could have significant implications for the implementation of AI in teaching and learning processes.
An interesting feature of the report is the exception for open source AI systems. Although these are generally exempt from certain provisions of the AI Regulation, there are also restrictions here that must be taken into account when applying them. Dr. Peter Salden, project manager of the KI:edu.nrw project, emphasizes that the report is not only important for German universities, but also provides relevant insights for schools and adult education institutions.
Background and funding
The report was prepared as part of the KI:edu.nrw project, which is funded by the Ministry of Culture and Science of North Rhine-Westphalia. The publication not only provides a valuable basis for educational institutions to protect themselves legally, but also enables an informed approach to the challenges and opportunities that artificial intelligence brings with it.
To find out more about the details and the full scope of the report, the full text is available on the KI:edu.nrw website. This represents an important resource for all educational institutions preparing to integrate AI technologies or already working with them.