Discover our new Policy Prototyping report on the EU AI Act's value chain requirement  

Read and download here
Yutong Liu Digit Digital Nomads Across Time 2560x1440
19.11.2025

The AI Act’s AI literacy obligation in 4 steps

Introduction

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 a practical tool. This tool explains the obligation under Article 4 of the AI Act step by step. In four steps, you will learn, among others, what AI literacy means, what minimum requirements apply, and which best practices you can follow. 

Four steps to explore the AI literacy obligation

In four steps, 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 AI literacy obligation entail?
  2. How to meet the AI literacy obligation?
  3. Who will enforce the AI literacy obligation, and when?
  4. What are the penalties for non-compliance with the AI literacy obligation?

Digital Omnibus

On 19 November 2025, the European Commission submitted a proposal to simplify and streamline digital regulations, aiming to strengthen the competitiveness of European businesses. The obligation under Article 4 of the AI Act is also under discussion. Currently, Article 4 requires providers and deployers to ensure AI literacy among their staff and others who use AI systems on their behalf. 

In the proposal, the European Commission takes stakeholder feedback into account and acknowledges that this obligation imposes an additional compliance burden, especially for smaller businesses. The Commission further emphasizes that AI literacy should be a strategic priority within organisations, regardless of legal obligations and potential penalties for non-compliance. In other words, the Commission and Member States should encourage AI literacy rather than enforce it for providers and deployers. This can be achieved by offering training, information resources, and other non-binding initiatives. The European A Board facilitates this through regular exchanges between the Commission and Member States. The Apply AI Alliance complements this by allowing discussion with the wider community. 

Important: The Digital Omnibus is currently only a proposal. Providers and deployers must still comply with the original obligation under Article 4 of the AI Act. 

Current application of Article 4: 

Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be used.”  

Proposed application of Article 4: 

The Commission and Member States shall encourage providers and deployers of AI systems to take measures to ensure a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, level of education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be used.” 

Downloads

The AI Acts literacy obligation in 4 steps (pdf, 152KB)

Download

Over

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

Authors

Shannen Verlee
Sultan Erdogan
Koen Vranckaert