Navigating AI Literacy Under the EU AI Act: What Article 4 Means for Organizations
With the AI Act set to become effective, organizations across the EU must prepare for the compliance requirements that come with it. A key provision in this legislation is Article 4, which centers on AI literacy—an obligation that businesses need to take seriously to ensure their workforce is adequately prepared to work with AI systems.
What is Article 4 of the AI Act?
Article 4 of the EU AI Act, set to take effect on February 2, 2025, requires that organizations ensure their employees possess a sufficient level of AI literacy. This means that all personnel involved in the deployment or operation of AI systems must have the skills, knowledge, and understanding necessary to work effectively with AI, in accordance with the regulations. In short, this provision aims to make sure that employees are not only capable of using AI systems but are also aware of the risks and ethical considerations associated with these technologies.
”Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be used.” (Article 4 AI Act)
According to the AI Act, "AI literacy" includes “skills, knowledge, and understanding that allow providers, deployers, and affected persons [...] to make an informed deployment of AI systems, as well as to gain awareness about the opportunities and risks of AI and possible harm it can cause.” (Article 3 (56) AI Act) This definition underscores the dual responsibility of understanding both the technical and ethical dimensions of AI systems.
Why Organizations Should Care
While the Act mandates AI literacy, the enforcement mechanisms surrounding Article 4 remain somewhat ambiguous. It's not yet clear how strict the penalties for non-compliance will be or how authorities will monitor compliance. However, failure to meet these requirements could result in legal consequences for organizations, especially those deploying high-risk AI systems, as oversight mechanisms may evolve over time.
But rather than viewing this obligation solely as a compliance burden, organizations should consider it a significant opportunity. By fostering AI literacy across their workforce, companies can not only avoid potential penalties but also accelerate AI adoption and drive innovation internally. AI literacy is essential for developing a deeper, more strategic understanding of AI’s capabilities—thus enabling businesses to harness its full potential.
Practical Steps to Achieve AI Literacy Compliance
1. Assess Existing AI Knowledge
Before diving into training, companies need to evaluate their employees’ current AI literacy levels. This can involve creating a detailed profile of each employee’s technical skills, experience, and familiarity with AI systems. One effective method could be deploying an internal survey or diagnostic tool that assesses the different dimensions of AI literacy, such as understanding of machine learning concepts, awareness of ethical implications, and experience with AI-based tools. This assessment can help identify gaps in knowledge and set benchmarks for progress. This profiling is also critical because it allows organizations to take a targeted approach rather than a generalized training, which might not address specific needs effectively. Often, organizations start by hosting an event where they introduce AI concepts, inspire employees, and allow for open discussions and feedback. Such events are excellent opportunities for employees to share their experiences and concerns, which can help kickstart AI initiatives in a positive and inclusive manner.
2. Tailored Training Programs
Once the assessment is complete, training should be customized to the specific needs of each group. For instance, employees with more technical roles might need in-depth training on data handling, AI model development, and the AI system lifecycle, while those in non-technical roles may require a broader understanding of AI’s business applications, potential biases, and ethical considerations. Training should cover both the legal aspects of the AI Act—such as understanding how AI can and cannot be used—as well as hands-on experience with the technologies they will interact with. Practical exercises, such as workshops, case studies, and scenario-based learning, can greatly enhance the effectiveness of these programs. By splitting employees into segments based on their roles and familiarity with AI, companies can ensure each person receives the right level of instruction to build confidence in working with these technologies.
3. Theoretical and Practical Education
A combination of theoretical knowledge and practical skills is crucial. Employees must understand not only the core principles of AI—such as how AI makes decisions, what constitutes an AI model, and the basics of machine learning—but also how to apply these principles in real-world scenarios. This helps employees become capable of bridging theory and practice, ultimately improving the organization’s capacity to work with AI effectively. For instance, practical training might involve sessions where employees interact with actual AI systems, understand their functionality, and troubleshoot simple issues that may arise. The goal is to create not only a technically competent workforce but also individuals who can critically assess AI outcomes, identify biases, and contribute to ethical deployment.
It is important to have different kinds of training, ranging from technical to non-technical, as well as training at the tool level. Training that goes more in the direction of prompt engineering, for example, can significantly boost productivity. Additionally, it is crucial to understand that when rolling out a new AI tool, employees should be trained on its use, much like they would be trained on how to use a new machine. Ensuring proper training for new AI tools can lead to more effective integration and utilization of these technologies in day-to-day operations.
4. Developing Internal Guidelines and Standards
Organizations should also consider developing internal codes of conduct or standards for AI usage. These internal frameworks help employees adhere to the necessary legal standards while providing a clear structure for the responsible use of AI technologies. Such guidelines could outline best practices for using AI responsibly, avoiding biases, and ensuring transparency in AI-driven decisions. For example, they might specify under what conditions employees are allowed to use AI-driven automation or what checks must be made before relying on AI-generated data. By establishing these internal standards, companies create a cohesive environment where AI is used consistently and ethically across different teams.
It is also quite common for organizations to develop guidelines that address how AI might impact employees, their jobs, or working conditions. These guidelines are often used as a commitment to AI literacy and to support the workforce rather than replace them. This approach can be a great way to communicate the organization's AI ambition and set the pace for AI initiatives. The recommendation is to develop these guidelines together with the organization's workers' council, if one is in place, to ensure alignment and foster a collaborative approach.
5. Ongoing Education and Certification
Given how rapidly AI evolves, continuous education and certification programs are essential. These can help ensure that employees stay updated on the latest AI developments and remain compliant with evolving regulations. Partnering with recognized institutions to provide certifications can also validate the organization’s commitment to maintaining a high level of competence among its workforce. Certifications serve as a formal acknowledgment of an individual’s capabilities in handling AI systems and can be particularly useful for roles involving higher accountability, such as AI officers or project managers. Additionally, establishing an internal culture of continuous learning—such as encouraging participation in workshops, online courses, and professional AI forums—ensures that employees maintain their AI literacy in the face of rapid technological changes.
Even though it can make a lot of sense to partner with external experts, not all training has to be external. Quite often, organizations educate their employees by doing "roadshows" where they showcase AI use cases they have developed and built, share their learnings, and also discuss their failures. Such roadshows can be an effective way to inspire employees and foster a culture of AI literacy within the organization. A good mix of internal and external training approaches can make a significant impact.
6. Appointment of an AI Officer
For larger organizations or those heavily reliant on AI, appointing an AI officer or manager can be a valuable step. Although not a formal requirement under the AI Act, having a dedicated individual to oversee AI projects, ensure compliance, and drive AI literacy within the company can prove highly beneficial. The AI officer acts as a bridge between technical teams, management, and compliance officers, ensuring that all AI initiatives are aligned with company objectives and regulatory requirements. The role involves not just overseeing current projects but also planning for future AI needs, identifying training requirements, and establishing a roadmap for compliance. This position becomes increasingly crucial for companies that use high-risk AI systems, as it ensures there is consistent oversight and an established point of accountability within the organization. This approach is not only relevant for larger organizations; many companies start with so-called AI ambassador programs to identify potential individuals who could take on this role and gradually skill them up. Larger organizations often have multiple AI ambassadors and consolidate these competencies in an AI Center of Excellence.
7. Establishing an AI Center of Excellence
In many larger organizations, an AI Center of Excellence (CoE) serves as a central hub for coordinating AI activities, providing training, and ensuring consistency in AI practices. The AI CoE is often responsible for overseeing the appointment and training of AI ambassadors, assessing skill gaps across departments, and developing tailored programs to address these needs. Additionally, the CoE plays a key role in communicating AI strategies and best practices throughout the organization, ensuring alignment between AI initiatives and business objectives. By centralizing expertise and resources, an AI CoE helps to drive AI literacy and supports the organization in moving forward with AI in a cohesive, strategic manner.
A Strategic Opportunity for Growth
While Article 4 presents an additional regulatory layer for companies, it’s also a unique opportunity. Organizations that proactively build AI literacy will find themselves better equipped to innovate, scale their AI initiatives, and remain competitive in an increasingly AI-driven world. The ability to effectively work with AI—from understanding its potential to mitigating its risks—gives companies a strategic advantage in the market. By treating AI literacy as a strategic initiative rather than a checkbox for compliance, companies can develop a culture that not only embraces AI but also uses it to drive long-term value.
In summary, while enforcement may still be unclear, the benefits of fostering AI literacy far outweigh the risks of non-compliance. Now is the time for companies to act, not only to meet legal requirements but to position themselves at the forefront of AI innovation in the coming years.
If your organization is looking to meet the AI Act’s AI literacy requirements and turn compliance into a strategic advantage, our academy programs can help. We provide tailored AI literacy training to ensure your team is equipped to work effectively, ethically, and confidently with AI systems. Whether you're an individual aspiring to lead AI transformation, consult organizations, or a company seeking compliance, our programs are designed to meet your needs. Get ahead of compliance and unlock your company’s AI potential—learn more about our programs today.
