Maryland AED Requirements 2026: What Chapter 91 Asks Of Your Organization
Short answer: As of October 1, 2026, Maryland Chapter 91 requires most organizations with a public access AED to hold a written AED plan, designate a trained AED Coordinator, maintain each device to manufacturer and FDA standards, and make sure people know where the AED is. There is no grace period.
Maryland House Bill 276, enacted as Chapter 91 of 2026, took effect on October 1, 2026. It rewrites the certificate requirements for the state's Public Access AED Program, and the change that matters most is not a new piece of equipment. It is a named person.
Until now, Maryland law spread AED responsibility across a facility. Chapter 91 concentrates it. The statute creates a defined role, the AED Coordinator, and attaches specific duties to that individual rather than to the organization in general. If your organization operates an AED in Maryland and nobody's name is on it, you are already out of step with the statute as written.
What the statute asks of a registered entity
Under the amended Education Article §13-517(e)(1), an entity other than a covered grocery store or restaurant must do all of the following to qualify for and retain its certificate:
| Requirement | What it means in practice |
|---|---|
| A written plan for AED use | The plan must include a requirement to notify the emergency medical services system through 911 as soon as possible when an AED is used. A verbal understanding does not satisfy this. |
| Maintenance, placement, operation and reporting procedures | Established as the EMS Board requires. The former reference to quality improvement procedures was removed. |
| A designated AED Coordinator | Defined in the statute as the individual designated to ensure compliance with the section. One named person, not a committee. |
| Coordinator maintains device functionality | Each AED and all related equipment and supplies, kept to the standards set by the device manufacturer and the FDA. Pads and batteries sit squarely inside this. |
| Coordinator promotes awareness | Of the location and operation of the AED, among potential or foreseeable operators. This is the requirement most organizations have no process for at all. |
| Coordinator training | An educational training course, plus any refresher courses, as required by the EMS Board. Grocery stores and restaurants covered by Health–General §21-330.3 are excepted from this. |
Public buildings also have to meet the naloxone co-location requirements of §13-518.
The awareness requirement is the sleeper
Four of the six items above are things a diligent organization probably already does in some form. Promoting awareness of the AED's location and operation among potential or foreseeable operators is different, because almost nobody has a repeatable process for it.
Think about what "foreseeable operators" means in a building with shift turnover. It is not the five people who were in the room when the AED was installed three years ago. It is whoever is working tonight. Satisfying this in good faith usually means folding AED location into new-hire orientation, posting location signage that is actually legible from a distance, and raising it at a recurring staff meeting rather than once a year.
Who is treated differently
Chapter 91 draws lines that matter for how you talk to your own organization, and getting them wrong means alarming people who are not affected.
Grocery stores and restaurants covered by Health–General §21-330.3 qualify for a certificate on two elements only: register the entity's name with the Program, and maintain the functionality of each AED and its related equipment and supplies to manufacturer and FDA standards. Their coordinators are not subject to the statutory training requirement. Note the limit of that carve-out, though: it governs certificate qualification. Those businesses still have to place the AED in a prominent area accessible to employees and customers under §21-330.3, and every registered entity still has to report each AED use to the Institute on the Institute's form.
MIEMSS defines the covered businesses by size. Restaurants with annual gross income above $1,000,000 excluding off-premises sales and more than 100 seats. Grocery stores with gross income above $10,000,000 that have either all major food departments, or at least one major food department plus at least 12,000 square feet.
Exempt from the certificate requirement entirely: jurisdictional EMS operational programs, licensed commercial ambulance services, health care facilities as defined in Health–General §19-114, and the place of business of practitioners licensed as dentists or physicians who are authorized to use an AED under that license. Chapter 91 also adds that a law enforcement agency may not be required to obtain a certificate for an AED deployed in a patrol vehicle. Read that one precisely: it covers the patrol vehicle, not a device mounted in the station lobby.
One thing to be careful about
Chapter 91 removed language from the statute that previously required a registered facility to ensure each individual expected to operate an AED had completed training and refresher training. It would be easy to read that as operator training no longer being required in Maryland. We would not read it that way, and we would not advise any client to act on it.
The state regulation, COMAR 30.06.02.01, as published, still requires that expected operators have completed CPR and AED training and subsequent refresher training, and still requires coordinator training consistent with current American Heart Association guidelines. Statute and regulation are two different instruments. Until MIEMSS amends the regulation, the safe and defensible position is that your people should still be trained. It is also the position you want to be in if an incident is ever reviewed.
What MIEMSS has and has not published
As of early October 2026, the MIEMSS AED Program page does not yet carry Chapter 91-specific guidance, a new coordinator course, or an implementation FAQ. What it does carry is the existing program framework: a two-step online registration, first the facility and then each individual AED, with approval taking up to two business days, and a coordinator duty list that includes monthly documented safety inspections, posting location details, ensuring a telephone is available for 911, and reporting every use.
If you are standing up a program against the new language, call MIEMSS directly at 410-822-1799 or email AED-Support@miemss.org and ask what the Board will accept as the coordinator training course. That answer is not yet on the website, and you want it in writing.
What happens if you do nothing
There is no fine attached to Chapter 91. The EMS Board may deny, suspend, revoke or refuse to renew a certificate for failure to meet the requirements, and may issue a cease and desist order or seek injunctive relief against an entity making automated external defibrillation available in violation of the section.
The real exposure is elsewhere. Maryland's civil immunity for a registered entity is conditioned on having satisfied the requirements for making an AED available under this section and holding a valid certificate at the time of the act or omission. Certificates run three years. An organization that lets its program drift is not just non-compliant on paper, it is standing outside the protection the statute was written to give it.
A first-90-days list for a new AED Coordinator
If your name just went on this, here is the order we would work it.
Week one. Open every cabinet. Write down the expiration date on each set of electrode pads and each battery, and the model and serial number of each device. Pad and battery expiration is the single most common gap we find, and it is the fastest one to close.
Week two. Confirm the entity is registered and that every individual AED is registered, not just the building. Confirm the certificate is current and note its expiry.
Weeks three and four. Write the plan. It does not need to be long. It needs to say who is notified, that 911 is called as soon as possible when a device is used, where each AED is, who inspects them and how often, and how a use gets reported to the Institute.
Month two. Start the monthly inspection log and keep it in writing. Book your own coordinator training.
Month three. Handle awareness. Signage, orientation, and a standing item on a recurring meeting agenda.
Where to go from here
Expiration dates on pads and batteries are the practical starting point for almost every program review, and they are also the thing a maintenance standard written around manufacturer and FDA requirements is really asking about. Always check the manufacturer's instructions for use for your specific model, since replacement intervals and self-test behavior differ between devices.
We have handled AED programs since 2003. If you want a second set of eyes on a Maryland program against the new statutory language, call us at 888-541-2337.
Sources
Maryland General Assembly, House Bill 276, enacted as Chapter 91 of 2026, enrolled chapter text. Approved April 14, 2026, effective October 1, 2026. The identical cross-file, Senate Bill 24, is Chapter 92. Maryland Institute for Emergency Medical Services Systems, Public Access AED Program. Code of Maryland Regulations 30.06.02.01. This article summarizes statutory requirements and is not legal advice.
Related reading: Is Your AED On The Map? How AED Registration Connects Your Device To 911 · Cardiac Emergency Response Plan Requirements for Schools · Owning AEDs Is Not A Program
