AI Literacy Obligation

Article 4 of the EU AI Act introduces a horizontal obligation for AI literacy that applies to all providers and deployers of AI systems, regardless of the system's risk classification. This makes it one of the first provisions to take effect and one of the broadest in scope within the entire Regulation.

The obligation requires providers and deployers to take measures to ensure, to their best extent, a sufficient level of AI literacy among their staff and other persons dealing with the operation and use of AI systems on their behalf. This obligation considers the technical knowledge, experience, education, and training of the relevant persons, as well as the context in which the AI systems are to be used, and the persons or groups of persons on whom the AI systems are to be used.

AI literacy, as envisioned by the Act, goes beyond mere technical competence. It encompasses the ability to understand AI systems' capabilities and limitations, to recognize potential risks, and to make informed decisions about their deployment and use. Organizations must develop training programmes that are proportionate to the role each person plays in relation to the AI system.

This obligation took effect on 2 February 2025, making it one of the earliest applicable requirements. Companies should document their AI literacy programmes as evidence of compliance, including training materials, attendance records, and periodic assessments. Failure to comply can result in administrative fines of up to 7.5 million EUR or 1.5% of annual worldwide turnover, whichever is higher.