European Commission’s Q&A on AI Literacy: A Comprehensive Overview
On May 7, 2025, the European Commission released a Q&A document addressing AI literacy obligations under the EU AI Act. This document aims to clarify the requirements set forth in Article 4 of the AI Act, detailing the measures necessary for entities to ensure compliance with AI literacy standards.
Key Objectives for AI Literacy Compliance
The European Commission outlines several critical steps that entities must take when developing and implementing an AI literacy compliance program:
- Ensure a general understanding of AI within the organization, covering topics such as:
- What is AI?
- How does AI work?
- What AI systems are utilized by the entity?
- What opportunities and risks does AI present?
- Consider the specific role of the entity in scope, whether as a provider or deployer of AI systems.
- Assess the risks associated with the AI systems provided or deployed, including vital questions such as:
- What knowledge do staff need when interacting with these AI systems?
- What are the potential risks, and how can they be mitigated?
- Develop an AI literacy compliance program that takes into account:
- The varying levels of technical knowledge, experience, education, and training of staff.
- The context in which the AI systems will be utilized and the specific individuals affected by these systems.
Training Requirements for AI Literacy
The European Commission emphasizes the necessity of frequent and specific training as part of AI literacy compliance programs. Merely directing staff to the instructions accompanying AI systems is generally deemed insufficient. The content of training programs is not static; it should vary based on the staff’s experience and must be evaluated on a case-by-case basis.
Additionally, training should address the risks associated with common generative AI systems, particularly issues such as hallucination. If third-party personnel interact with the AI systems, the entity may provide training directly or establish training requirements through contracts with those third parties.
Documentation and Compliance Monitoring
Entities in scope are required to record and document the measures taken to comply with Article 4 of the AI Act. However, it is important to note that external certification is not mandated.
Implementation Timeline
Article 4 of the AI Act came into effect on February 2, 2025, meaning that the obligations related to AI literacy are already applicable to relevant entities. However, the Q&A clarifies that supervision and enforcement rules will only commence from August 3, 2026. Penalties for non-compliance with AI literacy obligations will be determined by national laws, which EU Member States must adopt by August 2, 2025. Private enforcement is also possible if an individual experiences harm due to an entity’s failure to comply with these obligations.
This comprehensive overview of the European Commission’s Q&A on AI literacy underscores the importance of understanding and addressing AI technologies within organizations. By fostering a culture of AI literacy, entities can better navigate the complexities and risks associated with AI systems.
