The aim of this paper is to present challenges in the development process of an adaptive serious game called \E.F.A." which is directed to employees being responsible for workplace safety. The paper addresses the question of how already existing theories concerning adaptivity serve as a basis for the development of the serious game E.F.A. Therefore at  rst various theoretical models are explained, then the developmental approach is presented. The result is a set of learning and knowledge entries, tutorial information, and the learner information in a complex model. Finally challenges, limitations, and future research are discussed.