AI literacy is essential to ensure people are competent and knowledgeable about AI. With some sections of the EU AI Act set to take effect on February 2, 2025, businesses and organisations should already prepare for a new requirement: ensuring the AI literacy of staff or employees interacting with AI systems. In this article, we set out what the law requires you to do and explain how you might do it. We can help you ensure your staff’s AI literacy.
Organisations must ensure the AI literacy of their staff from February 2025.
This obligation reflects the EU’s commitment to responsible AI usage, aiming to equip employees with the knowledge to operate AI ethically, avoid unintended consequences, and understand the broader impacts on society.
The regulatory requirement for AI literacy
The regulation’s mandate for AI literacy is laid out in Article 4 of the EU AI Act, which requires that “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.”
The EU AI Act defines AI literacy in Article 3 para. 56 as “skills, knowledge and understanding that allow providers, deployers and affected persons, taking into account their respective rights and obligations in the context of [the EU AI Act], to make an informed deployment of AI systems, as well as to gain awareness about the opportunities and risks of AI and possible harm it can cause”. In other words, AI literacy is not just familiarity with AI; it includes a thorough understanding of its applications, benefits, and potential pitfalls, empowering employees to make responsible decisions when deploying or using AI systems.
European Artificial Intelligence Board “may … support the Commission in promoting AI literacy, public awareness and understanding of the benefits, risks, safeguards and rights and obligations in relation to the use of AI systems” (article 66(f))
“Deployers should ensure that the persons assigned to implement the instructions for use and human oversight as set out in this Regulation have the necessary competence, in particular an adequate level of AI literacy, training and authority to properly fulfil those tasks.” (recital 91)
“In order to obtain the greatest benefits from AI systems while protecting fundamental rights, health and safety and to enable democratic control, AI literacy should equip providers, deployers and affected persons with the necessary notions to make informed decisions regarding AI systems. Those notions may vary with regard to the relevant context and can include understanding the correct application of technical elements during the AI system’s development phase, the measures to be applied during its use, the suitable ways in which to interpret the AI system’s output, and, in the case of affected persons, the knowledge necessary to understand how decisions taken with the assistance of AI will have an impact on them. In the context of the application this Regulation, AI literacy should provide all relevant actors in the AI value chain with the insights required to ensure the appropriate compliance and its correct enforcement. Furthermore, the wide implementation of AI literacy measures and the introduction of appropriate follow-up actions could contribute to improving working conditions and ultimately sustain the consolidation, and innovation path of trustworthy AI in the Union. The European Artificial Intelligence Board (the ‘Board’) should support the Commission, to promote AI literacy tools, public awareness and understanding of the benefits, risks, safeguards, rights and obligations in relation to the use of AI systems. In cooperation with the relevant stakeholders, the Commission and the Member States should facilitate the drawing up of voluntary codes of conduct to advance AI literacy among persons dealing with the development, operation and use of AI.” (Recital 20)
Consequences of non-compliance with Article 4 EU AI Act
Article 4 commenced on 2 February 2025 but public enforcement will only start in August 2025. Before then private enforcement is possible. The Act holds key individuals, such as executives and managers, accountable for ensuring their teams possess sufficient AI literacy. This obligation implies that organisations not only need to educate employees but must also continuously evaluate and adapt these educational measures to meet evolving AI challenges and regulatory expectations.
Preparing for 2025: Compliance steps for organisations
The hard question is how are you going to do it?
There are many words in the EU AI Act. What does it actually mean? The EU AI Act’s AI literacy requirement is not just about training; it’s also a critical step towards fostering a culture of responsible AI usage. Organisations will need to start preparing for this compliance requirement by evaluating their workforce’s current AI understanding and identifying areas where targeted training is necessary.
An AI awareness training plan is crucial.
Actions you can take next
- Ensure your governing body (e.g., board) is AI literate by asking us to brief them.
- Ensure the AI literacy of your staff by asking us to help you train them (which might include a private workshop for them).
- Book to attend our event Managing an AI training programme.
- Plan your AI awareness training programme by asking us to guide you or by joining our Trustworthy AI programme and working through the module on Managing an AI Training Programme.
- Enhance your understanding of the EU AI Act by delving deeper into the legislation.
- Evaluate the current AI understanding of your employees and identify areas where training is necessary. On that basis, implement customised training programmes. Michalsons is happy to assist you in that process.
- Explore the potential impacts on your industry by staying informed about the developments in AI legislation through our newsletter.