AI literacy (EU AI Act Article 4)
Knowledge is essential to use AI responsibly. AI literacy helps people assess whether using AI is a good or bad idea and how to use the technology correctly. Since 2 February 2025, every company in the EU must take measures to ensure that its employees and end users develop sufficient AI literacy. Abdullah Elbi and Sultan Erdogan of KU Leuven CiTiP outline the requirements and set you on your way. (Updated on 27 July 2026 following the changes introduced by the Digital Omnibus Proposal on AI.)
“ Being ‘AI literate’ becomes, therefore, as essential as traditional literacy skills like reading, writing, and arithmetic. ”
The EU AI Act mandates AI literacy
The EU AI Act, world’s first regulatory framework for AI, defines the rules for using and developing artificial intelligence in Europe. The goal: to ensure safe, reliable, and transparent use of AI while respecting fundamental rights and values in Europe.
Who does this law apply to?
Article 4, the first substantive article in the EU AI Act, requires both providers and deployers of AI systems to take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, considering the persons or groups of persons on whom the AI systems are to be used.
What is AI literacy?
AI literacy goes beyond purely technical knowledge. It includes the ability to:
- enable an informed deployment of AI systems,
- understand the opportunities of AI,
- know the risks and potential harm caused by AI technologies.
Aside from technical knowledge, AI literacy also involves understanding the broader implications of AI systems and the decisions they make (or assist in making) about individuals and groups, explain Elora Fernandes and Abdullah Elbi from KU Leuven’s Centre for IT & IP Law (CiTiP).
Article 4 has taken effect as of 2 February 2025.
Digital Omnibus Proposal amends original text
As of 27 July 2026, following the publication of the Digital Omnibus Proposal on AI, the European Commission made some changes to the EU AI Act, as part of other recent proposals intended to simplify EU digital rulebook while strengthening EU competitiveness.
- The wording was changed from "take measures to ensure to their best extent a sufficient level of AI literacy" into "take measures to support the development of AI literacy".
New lines were added:
- This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual.
- The Commission and the Member States shall support and facilitate the efforts of providers and deployers of AI systems, in particular SMEs, in fulfilling their obligation on AI literacy. The Commission shall publish practical examples of how to comply with that obligation.
- The Board shall adopt recommendations, taking into account European competence frameworks, to support the Commission and Member States in the promotion of AI literacy.
Why is AI literacy Important?
The European Union highlights three key reasons for promoting AI literacy among professionals in Europe:
- Maximizing the benefits: Europe aims to fully leverage the benefits of AI systems while protecting fundamental rights, health, safety, while enabling democratic oversight of AI systems.
- Ensuring compliance with the AI Act: AI literacy helps professionals to implement and enforce the AI Act correctly.
- Improving working conditions and fostering innovation: ensuring that trustworthy AI continues to develop and innovate within Europe.
AI literacy is not just about technical skills. It enables people to participate actively in the social, cultural and political ecosystems of the 21st century, explain Fernandes and Elbi (KU Leuven CiTiP). AI literacy helps individuals become more autonomous and independent in the digital society.
Which measures support the development of AI literacy?
Article 4 states that de development of AI literacy must be “supported”, but it leaves the specific implementation up to organisations. This depends on several factors:
- Which AI systems are currently in use or planned?
- What are the risks associated with these AI systems? (As outlined in the EU AI Act)
- The level of AI knowledge that your employees already have
- What is each employee’s role concerning the AI system? (Developer, decision-maker, user, end user, or indirectly impacted individual?)
How to develop AI literacy in your organisation
Know your staff and the way they use AI
- Identify the use of AI in your organisation
Which AI systems are currently in use? How and by whom? Also, consider shadow AI systems - AI tools that employees use without the organisation’s awareness. - Assess the risks to human rights of each AI system (AI Act)
Examine the data used (personal or not) and assess the system’s safety, reliability, and transparency. Regularly evaluate these aspects. Are there high-risk AI systems? Designate individuals responsible for human oversight. - Evaluate the AI knowledge within your teams
How much do your employees already know about AI? Where are the knowledge gaps? - Determine the AI role of each employee
Are they end users, active users, developers, decision-makers, or human overseers? - Define learning needs for each role
The AI Act asks for "tailored efforts", meaning that AI literacy levels should be adapted to each role's responsibilities. Determine the necessary knowledge and skills for each function. This will differ between marketers, HR staff, technical teams, and executives.
Provide training & learning opportunities
The law refers to “measures,” meaning efforts are not limited to traditional training alone.
- Offer a broad AI literacy foundation (e.g. Elements of AI)
- Opt for diverse learning methods, tailored to the different roles: traditional courses, peer knowledge-sharing, internal knowledge databases, experimentation spaces…
- See learning as an ongoing process. AI technology evolves quickly, and staff come and go or switch roles. Keep training continuous and adaptable.
- Strengthen digital skills. Do some of your employees lack essential digital skills? Address these gaps to ensure everyone can engage with AI effectively.
- Build on existing initiatives. You may already invest in GDPR, cybersecurity, and digital transformation training. Extend these efforts to AI literacy.
- Connect different departments
Legal teams should understand what IT is deploying, while HR should know how to keep human oversight over their AI-driven hiring tools, in compliance with the AI Act...
What else can you do to improve AI literacy?
- Inform "third parties". Are your suppliers, customers, target groups or any other parties affected by decisions made by an AI system? They too must be kept adequately informed. Also bear in mind the GDPR rules on personal data use.
- Document everything. Keep a record of the AI training courses attended by your staff. This ensures you are always compliant with the regulations.
Other relevant regulations
Human Oversight (EU AI Act Art. 14)
For high-risk AI systems affecting human rights, Article 14 on human oversight comes into play. This article ensures that AI systems do not operate autonomously without human intervention. To effectively oversee an AI system, a human supervisor must have sufficient knowledge and insight to:
- understand how the system works
- monitor the outputs of the system
- correct the system if it generates unintended or harmful results
Context matters: The level of AI literacy required depends on how reliable the system is and how significant its decisions are. The more critical the decision, the deeper the human understanding needed.
Additionally, developers of high-risk AI systems must provide transparent and explainable interfaces so users can understand how the system operates.
GDPR
The AI Act is "new regulation that applies alongside and does not modify existing laws such as the General Data Protection Regulation" (GDPR), says Isabela Maria Rosal from KU Leuven CiTiP: just because something is allowed under the AI Act doesn’t mean it complies with GDPR - and vice versa. However, the frameworks are aligned: individuals must be informed of how their data is processed via AI (Article 13(2)(f) GDPR).
This includes:
- which data is collected,
- the purposes of data collection,
- how algorithms will generate new data,
- how algorithms make decisions, and their impact on people and society,
- the broader societal implications of AI processes.
How will Article 4 be enforced?
The EU AI Act, Article 4, has taken effect on 2 February 2025. Currently, there are no direct penalties for non-compliance, but market surveillance authorities may factor in AI literacy obligations when investigating AI-related violations (Articles 99 and 85). Fines could be introduced in the future, so organisations are strongly advised to comply proactively.
For now, the EU is relying on voluntary codes of conduct, developed by the European AI Office and the member states, such as the General-Purpose AI Code of Practice ⇗ and the Code of Practice on Transparency of AI-Generated Content ⇗. In Belgium/Flanders, it is still unclear which authority will be responsible for enforcement at the regional level.
AI literacy is a crucial competence
AI literacy is not optional, it is a crucial competence for anyone working with or affected by AI. Since 2 February 2025, organisations in the EU are legally required to promote AI literacy. Now is the time to build a future in which AI is used responsibly, transparently and effectively. Don’t treat AI literacy in isolation - integrate it into a broader learning culture that includes GDPR, cybersecurity, and future digital innovations. While investing in AI literacy today, organisations and professionals will reap the long-term benefits of lifelong learning about AI.
Sources
- The Artificial Intelligence Act ⇗ (EU AI Act Regulation 2024/1689).
- Artificial Intelligence Literacy Act 2023 ⇗: Artificial Intelligence Literacy Act HC Bill (202312-14) [H.R.6791], US Congress.
- Council of Europe Framework Convention ⇗ on Artificial Intelligence and Human Rights, Democracy and the Rule of Law, (September 2024).
- Fernandes, Elora; Elbi, Abdullah; This Time, Humans Learn About Machines: AI Literacy in the AI Act (Part 1 & 2) ⇗.Publisher: KU Leuven CiTiP Blog
- Elora Fernandes, Wayne Holmes, et al., 'Chapter I. General Provisions, Article 4 AI Literacy', in Nikolaus Forgo, CeyhunNecatiPehlivan, et al. (eds), The EU Artificial Intelligence (AI) Act: A Commentary, (© 2024 Kluwer Law).
- AI Strategy Institute, AI Literacy Under the AI Act ⇗, Webinar, 18 December 2024. https://www.linkedin.com/event...
- The impact of the AI Act in 6 steps ⇗, Knowledge Centre Data & Society
- The AI Act’s AI literacy obligation in 4 steps ⇗, Knowledge Centre Data & Society.
- AI Literacy - Questions & Answers ⇗, European Commission.
- brAInfood - Digital Omnibus on AI: (new) deadlines AI Act ⇗, Knowledge Centre Data & Society.
- The Digital Omnibus on AI ⇗, European Commission.
Read more
What is the AI Act?
The EU AI Act (Artificial Intelligence Act) is the world's first legal framework for artificial intelligence. It addresses AI-related risks to ensure safe, reliable, and transparent AI usage while respecting fundamental rights and values in Europe. The AI Act will be rolled out between August 2024 and August 2027.
How to increase AI Literacy in your company? Answer: training programmes and a learning culture
From February 2025, AI literacy is mandatory under the European AI Act. How do you deal with this in your company? Nadja Desmet of Someflex provides some tips on how to have a good training programme and a suitable learning culture.
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Abdullah Elbi
Abdullah graduated from Bilkent University, Faculty of Law. He is a qualified lawyer in Turkey who is experienced in privacy and data protection law. As a Jean Monnet scholar, Abdullah completed his master's degree at Leiden University, specialising in Law and Digital Technologies.
He is interested in biometrics and data protection, with a particular focus on the effects of new technologies on vulnerable groups. Before joining CiTiP, Abdullah was actively involved in The Netherlands Red Cross, 510 initiative’s works, and he contributed to several projects to ensure the responsible use of data and digital technologies in the humanitarian sector while respecting fundamental human rights and data protection standards.
Abdullah joined CiTiP in October 2021 as a legal researcher, where he is primarily involved in the Horizon 2020 project iMars and The Research Council of Norway-funded SALT Project.
Research interests: regulation of AI, GDPR, fundamental rights impact assessments, cyber security, biometrics, synthetic data, emotion recognition, eID legal framework
Sultan Erdogan
Sultan Erdogan is a researcher at KU Leuven’s Centre for IT and IP Law (CiTiP) and works at the Knowledge Centre Data and Society. As part of her tasks for the Knowledge Centre, she informs Belgian and Flemish stakeholders (policymakers, industry, public institutions, and the general public) about the legal aspects of data-driven and AI applications.
Isabelle Borremans
Isabelle is not an AI expert, but she has been communicating about AI (and AI training) for VAIA for four years. So, she knows exactly how to communicate effectively about AI training. Feel free to contact her with any questions on how to promote your AI course. She’ll gladly challenge you with questions like:
- Who is your target audience? Can you be more specific?
- What networks reach that audience?
- Where does your audience prefer to take courses?
- What AI skills does your audience need?
- Does your training match their needs?
Besides communication, Isabelle also works on VAIA’s strategy: Who is our audience? How can we reach them? How can we spark their interest in AI?
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