European Commission’s Q&A on AI Literacy
On May 7, 2025, the European Commission published a comprehensive Q&A regarding the AI literacy obligation defined under Article 4 of the AI Act. This document serves as a critical guide for organizations involved with AI systems, building on previous guidance provided in a webinar held in February 2025.
Key insights from the Q&A emphasize the importance of AI literacy across various sectors. The obligation to ensure AI literacy commenced on February 2, 2025, although enforcement by national market surveillance authorities will not begin until August 3, 2026.
Understanding the AI Literacy Requirement
The AI literacy requirements apply universally to all providers and deployers of AI systems. This mandate entails that organizations must train all personnel directly interacting with AI technologies. The scope of this requirement extends beyond employees, encompassing contractors and service providers as well.
Components of an Effective AI Literacy Program
While the European Commission does not stipulate specific content for AI literacy programs, it suggests that a robust program should:
- Ensure a general understanding of AI within the organization;
- Consider the organization’s role, whether as a provider or deployer of AI systems;
- Account for the risks associated with the specific AI systems in use;
- Develop AI literacy actions based on these factors, considering staff’s technical abilities and the contexts in which AI systems are applied.
Organizations are not mandated to issue training certificates as proof of completing AI literacy training; maintaining internal records of training and initiatives is deemed adequate.
Limitations of Current Training Approaches
Relying solely on the instructions for AI systems or simply encouraging staff to read them may prove ineffective. A more comprehensive approach is necessary to achieve an adequate level of AI literacy.
Compliance for Organizations Using Generative AI
Organizations deploying generative AI systems—for instance, in tasks such as generating advertising text or translating content—must adhere to the AI literacy requirements. This includes educating staff on specific risks associated with these technologies, such as hallucination, which refers to the generation of misleading or incorrect information by AI.
Role of National Market Surveillance Authorities
National market surveillance authorities will oversee compliance with AI literacy regulations. The AI Act mandates that member states appoint these authorities by August 2, 2025. Even though the obligation for AI literacy is already in effect, the enforcement will not commence until August 3, 2026.
As the landscape of AI regulation continues to evolve, staying informed about these developments is crucial for organizations navigating the complexities of AI compliance.
