The AI Act’s AI literacy obligation in 4 questions

How can you ensure that your organisation complies with the European requirement for AI literacy? The answer is not straightforward. To support organisations in developing an AI literacy policy, the Knowledge Centre Data & Society has created an information sheet. This information sheet explains the obligation under Article 4 of the AI Act. With four questions, you will learn, what AI literacy means and what minimum requirements apply, as well as other related information.. 

In four questions, we explore the AI literacy obligation, so that organisations understand what the obligation entails and know how to ensure that their staff and other stakeholders have the required level of AI literacy.

1. What does the EU AI literacy requirement mean? 
2. How can organisations meet the EU AI literacy requirement? 
3. Who monitors compliance with the EU AI literacy requirement? 
4. What are the penalties for non-compliance with the EU AI literacy requirement? 

The European Commission considers AI literacy to be a key objective of European AI policy. The requirement regarding AI literacy, set forth in Article 4 of the AI Act, took effect on 2 February 2025. This provision was subsequently amended via the Digital Omnibus on AI. This Omnibus is part of the broader Digital Omnibus package, which was proposed on 19 November 2025, to simplify digital regulations. In this context, several targeted amendments are being made to the AI Act. 

One of these amendments relates to AI literacy. The original Article 4 of the AI Act required providers and deployers of AI systems to ensure that individuals working with AI systems on their behalf possess a sufficient level of AI literacy. The amended provision relaxes this requirement. From now on, providers and deployers must take measures to support the development of AI literacy among individuals working on their behalf, without requiring a specific level to be achieved.   

In addition, both the European Commission and the member states will play a greater role in promoting AI literacy. To support this task, the AI Board will draft recommendations. According to the Commission, this amendment will help reduce the administrative burden on organisations. 

Important: AI literacy remains a requirement, but it should be understood as a best-efforts obligation. The emphasis here is on support from the European Commission and the Member States, rather than on sanctions. In addition, the obligation for deployers of high-risk AI systems to entrust human oversight to individuals with the required competence remains in full force (Article 26(2) of the AI Act). Finally, Article 4 of the AI Act does not impose any obligation to systematically measure or evaluate the AI knowledge or skills of staff. 

 In short, the main differences between the old and new Article 4 of the AI Act are: 

1. There is no longer an obligation to achieve a specific level of AI literacy within an organisation (Article 4(1) of the AI Act); 
2. The European Commission and the member states will support and facilitate the efforts of providers and deployers by publishing practical examples on the central information platform (Article 4(2) of the AI Act); 
3. The AI Board will support the Commission and the member states in their mission by issuing recommendations on this matter (Article 4(3) of the AI Act). 

This publication was originally published in the fall of 2025. In August 2026, this publication was updated. The updated version replaces the previous version. 

Image: Yutong Liu & Digit / https://betterimagesofai.org / https://creativecommons.org/licenses/by/4.0/