On Could 7, 2025, the European Fee printed a Q&A on the AI literacy obligation underneath Article 4 of the AI Act (the “Q&A”). The Q&A builds upon the Fee’s steerage on AI literacy offered in its webinar in February 2025, coated in our earlier weblog right here. Amongst different issues, the Fee clarifies that the AI literacy obligation began to use from February 2, 2025, however that the nationwide market surveillance authorities tasked with supervising and implementing the duty will begin doing so from August 3, 2026 onwards.
Key issues from the European Fee’s Q&A on AI literacy are as follows:
- AI literacy necessities apply to all suppliers and deployers of AI programs. In sensible phrases, it requires organizations to coach anybody instantly coping with AI programs. This requirement covers not solely staff, but in addition, for instance, contractors and repair suppliers interacting or utilizing AI programs.
- There aren’t any particular necessities on what an AI literacy programme ought to embrace to adjust to AI literacy necessities. But, the European Fee considers that, at a minimal, an AI literacy programme ought to:
- guarantee a common understanding of AI throughout the group;
- contemplate the position of the group (e.g., as supplier or deployer of AI programs);
- have in mind the danger of the actual AI programs offered or deployed within the group; and
- construct AI literacy actions based mostly on the components listed above, contemplating, amongst different issues, the workers’s technical capabilities and the context by which the AI programs are used.
- Organizations aren’t required to situation a coaching certificates or comparable credentials to show that workers have accomplished AI literacy coaching. Inner information of trainings and different initiatives are enough.
- Merely counting on AI programs’ directions to be used or asking workers to learn them is perhaps ineffective and inadequate to offer an sufficient stage of AI literacy.
- Organizations whose staff deploy generative AI programs for duties corresponding to writing promoting textual content or translating content material should adjust to AI literacy necessities, together with informing workers about particular dangers, corresponding to hallucination.
- Nationwide market surveillance authorities are tasked with overseeing AI literacy compliance. The AI Act requires Member States to nominate these nationwide market surveillance authorities by August 2, 2025. Though the AI literacy obligation already applies as of February 2, 2025, supervision and enforcement of this obligation by market surveillance authorities will solely begin on August 3, 2026.
* * *
The Covington staff continues to observe regulatory developments on AI, and we commonly advise the world’s high know-how firms on their most difficult regulatory and compliance points within the EU and different main markets. When you have questions on AI regulation, or different tech regulatory issues, we’re completely happy to help with any queries.
This weblog publish was written with the contributions of Alberto Vogel.
