If your organisation is covered by the Welsh Language Standards and you build an induction or health and safety module in English, a duty crystallises immediately to offer the same training in Welsh. Not eventually, and not on request. The wording in the health regulations is blunt: “You must provide opportunities for training in Welsh in the following areas, if you provide such training in English”, and induction and health and safety are both on the list.
Key takeaway: The trigger is building the English version. Running it through a translation engine does not discharge the duty, because the regulator has named unreviewed automated translation as a compliance failure in its own right. Author in both languages from the start and the problem disappears.
Who this applies to, and since when
The Welsh Language (Wales) Measure 2011 gives Welsh official status in Wales and requires that it is “treated no less favourably than the English language” (legislation.gov.uk). The standards that follow from it arrived sector by sector:
| Sector | Regulations | Compliance from |
|---|---|---|
| Local authorities and national parks | No. 1 Regulations 2015 | 30 March 2016 |
| Further and higher education | No. 6 Regulations 2017 | 1 April 2018 |
| NHS Wales health boards, trusts, CHCs, Social Care Wales | No. 7 Regulations 2018 | 30 May 2019 |
The perimeter widened again in 2025. Amendment regulations made in March 2025 brought Special Health Authorities into the health standards and placed Health Education and Improvement Wales under the education ones (WSI 2025/339), so a body that checked its position a few years ago may now be in scope.
Note that “no less favourably” is a quality test, not a presence test. The website standards require Welsh pages to be “fully functional”, not merely to exist. A Welsh module that loads but reads strangely, uses the wrong terminology or has a broken interaction is arguably non-compliant even though someone can point at it.
The training standards, quoted properly
This is the part most organisations have not read, and it is unusually specific.
Standard 97 in the health regulations: “You must provide opportunities for training in Welsh in the following areas, if you provide such training in English: (a) recruitment and interviewing; (b) performance management; (c) complaints and disciplinary procedures; (ch) induction; (d) dealing with the public; and (dd) health and safety” (Schedule 3, No. 7 Regulations).
Standard 96: “You must assess the Welsh language skills of your employees.”
Standard 102 requires awareness training covering the history and role of Welsh in Welsh culture, the organisation’s duty to operate in accordance with the standards, and how Welsh can be used in the workplace.
Standard 106 requires every new or vacant post to be categorised as Welsh skills essential, to be learnt, desirable, or not necessary.
The education regulations carry the same duties at standards 134, 135, 138 and 140, and the local government regulations at 127, 128, 130 and 132. The wording is near identical across all three, which is convenient: one argument covers a health board, a college and a council.
Two observations for anyone planning content. First, induction and health and safety are exactly the two subjects most organisations build first, so the duty bites earlier than people expect. Second, standard 102 requires training about the Welsh language itself, which is content that cannot plausibly survive being machine translated, because the subject matter is the language.
What the regulator says about machine translation
The Welsh Language Commissioner published a regulatory policy statement on artificial intelligence in July 2025, and it addresses this directly. Among the practices it names as a compliance risk: “Automated translation without human review: Using AI models to translate documents or official communications without human review”, because it “can lead to linguistic errors or inaccuracies” (Welsh Language Commissioner).
The same statement sets three expectations that are worth quoting in any procurement document: organisations must “guarantee that AI systems use Welsh correctly and naturally, avoiding linguistic errors”; they must conduct “regular reviews by competent Welsh speakers of AI-generated content”; and they remain “accountable for their use of AI”. That last one matters commercially. The duty does not transfer to your software vendor.
The Commissioner’s longer-standing guidance on bilingual drafting is harder still: “translation generated through machine translation should not be regarded as accurate or generated to an acceptable standard”, and machine output “should not be published without it being edited thoroughly by a human translator” (Welsh Language Commissioner guidance).
That same guidance offers the solution in a single sentence, and it is the argument of this entire post: “Usually, the easiest way of providing bilingual texts for the public is to encourage officers to draft text bilingually from the very beginning. This is certainly the best way of ensuring that the organisation does not need to depend on translating everything.”
It also makes a point that bilingual organisations know and monolingual vendors forget: “It is important to realise that not everyone who speaks two languages can necessarily translate. Translation is a specialist profession.”
Why a vendor’s language count is not the answer
Several immersive and authoring platforms now advertise automatic translation into twenty five or forty languages. Welsh is usually on the list. That is a genuinely useful feature and it is not the same thing as meeting the standards.
The gap is terminology and register. The Welsh Government runs its own translation service resources at BydTermCymru, publishing the TermCymru terminology database, the Yr Arddulliadur style guide, and 144 shared translation memories, free for translators to reuse (Welsh Government). It also funds domain-specific machine translators for health and care, and for legislation, precisely because general purpose engines do not know sector vocabulary.
The Welsh Government’s own assessment is carefully hedged. Its technology action plan final report notes that recent improvements “reduce the amount of post-editing needed” and that domain focus improves results, framing the technology as assisting human translators rather than replacing them (Welsh Government). Its current action plan commits to working with Microsoft to “improve how Copilot processes Welsh”, which is an implicit acknowledgement that mainstream models are not there yet.
One practical trap: Cysgliad, the Welsh proofing suite, is free to individuals, schools and organisations with fewer than ten employees. A health board, a college or a council is over that threshold and needs a licence.
Where organisations are actually falling short
The Commissioner’s 2024-25 assurance report gives a useful picture, and it is not the one people expect (Welsh Language Commissioner).
Public-facing digital compliance is improving fast. Across health boards, documents available in Welsh rose from 68% to 80%, web pages from 74% to 87%, and social media from 64% to 80%.
Internal capacity is where it stalls. All ten health boards reported low or medium assurance on reception and telephone services, with recruitment of Welsh speakers the main obstacle. On workplace use, 69% of organisations claimed high compliance on fostering Welsh skills, but the Commissioner found that policies “do not always achieve the core aim” of expanding daily Welsh use, and called for “practical and measurable schemes”. In further education, compliance on Welsh language forms sat at 57%, the weakest area in the education sector, though up from 38%.
The Commissioner can require an action plan, require specific steps, publicise a failure, and impose a civil penalty of up to £5,000 (enforcement policy). The reputational element usually matters more than the penalty.
The clinical argument, which is stronger than the compliance one
More than just words, the Welsh Government’s framework for Welsh in health and social care, runs to 2027 and is built around the active offer, defined as “providing a service in Welsh without someone having to ask for it. It means creating a culture that places the responsibility on health and social care providers to provide a proactive language offer so that people can access care, as equal partners, through the medium of Welsh” (Welsh Government).
The framework’s own ministerial foreword makes the case in clinical rather than cultural terms: a person with dementia being cared for in English may not fully understand what is happening to them, which could affect their clinical outcomes. Language is a clinical variable, not a courtesy.
That reframes staff training. If the active offer is the goal, then scenario training where a patient speaks Welsh first is not a translated version of the English scenario. It is a different scenario, with a different decision at the start. You cannot get there by translating a script.
A December 2025 written statement from the Cabinet Secretary for Health and Social Care confirmed that mandatory Welsh language awareness training completion across NHS Wales is at its highest recorded level, and set the focus for the final two years of the plan on implementing standard 110, the duty to publish a five-year plan on the ability to offer clinical consultations in Welsh (Welsh Government).
How many Welsh speakers, and why the two numbers differ
You will see two figures quoted, sometimes in the same document, and they are 300,000 apart.
The 2021 census recorded 538,000 people aged three and over, or 17.8%, able to speak Welsh, down from 562,000 and 19.0% in 2011 (ONS). The Annual Population Survey for the year ending March 2026 put it at 843,700 people, or 27.3% (Welsh Government).
Welsh Government treats the census as “the key source of information to measure the number of Welsh speakers in Wales”, and notes the divergence between census and household surveys is longstanding. The survey has also lost its accredited statistics status due to falling sample sizes and now carries increased uncertainty.
If you are writing a business case, use the census figure and say which you used. A vendor quoting 850,000 without the caveat has not read the source.
What is coming
The Welsh Language and Education (Wales) Act 2025 received Royal Assent on 7 July 2025 and puts the million-speaker target into statute (legislation.gov.uk). It is only partly in force. The National Institute for Learning Welsh arrives in August 2027, and a code describing Welsh language ability based on the Common European Framework is still to commence.
That code will interact directly with standards 96, 127 and 134, the duties to assess employees’ Welsh skills. Organisations still using a homegrown zero to five scale should expect to remap.
For colleges, Medr’s Welsh Language Condition, published in March 2026, now requires registered providers to publish and maintain a Welsh Language Strategy reviewed every five years, monitored through annual assurance returns (Medr).
The short answer
The standards require training in Welsh wherever you provide it in English, and they name induction and health and safety explicitly. Machine translation without human review has been named by the regulator as a compliance risk, and accountability stays with you rather than your vendor. The workable approach is the one the Commissioner recommends: author bilingually from the beginning, with Welsh speakers writing Welsh, using the Welsh Government’s own terminology resources, so there is nothing to retrofit.
We build scenarios bilingually rather than translating them afterwards. The bilingual glossary entry has the short definition, and the health and social care education pages cover how Welsh scenarios are being used.