Until 27 July 2026
Ensuring a sufficient level
The original text asked organizations to ensure, as far as possible, a sufficient level of AI literacy among their staff and others who work with AI on their behalf.
AI literacy: what the EU AI Act asks and how to organize it
AI literacy helps your people work faster and more safely with AI. Here you can read what article 4 of the EU AI Act asks of your organization after the change of 27 July 2026, what works in practice and how to show which measures you took.
- Updated on
- With sources from EUR-Lex and the European Commission
What is AI literacy?
AI literacy means your people know what AI can and cannot do, how to use it responsibly and what their own role is. An AI-literate colleague knows why a language model is sometimes convincingly wrong, which data does not belong in a chatbot and when to double-check an outcome.
For organizations, the AI Act, the European AI regulation, also covers it. Article 4 asks you to take measures for the AI literacy of everyone who works with AI on your behalf. Which measures fit depends on your people and on how you use AI.
What does article 4 of the EU AI Act ask?
Article 4 of the AI Act is about AI literacy. It has applied since 2 February 2025 to organizations that provide or use AI. On 27 July 2026, the article was amended by the Digital Omnibus on AI, Regulation (EU) 2026/1744.
Since 27 July 2026
Taking measures to support AI literacy
The new text asks organizations to take measures to support the development of AI literacy. They take into account the knowledge, experience and training of their people, the context and the people on whom the AI is used.
Providers and deployers do not have to ensure a specific level of AI literacy for each person. The new text says so explicitly.
Source: Regulation (EU) 2026/1744, article 1, point 5, on EUR-Lex (opens in a new tab)
What this means in plain language
Is AI literacy required?
Yes: taking measures is required. The law leaves the form up to you. Below you see per topic what the law asks and what we advise.
| Topic | What the law asks | What we advise | Source |
|---|---|---|---|
| Measures for AI literacy | Required since 2 February 2025, for everyone who works with AI on your behalf. | First map which AI you use and who works with it. | AI Act, article 4 |
| Level for each person | No fixed level. Since 27 July 2026, the law says so explicitly. | Tailor it per role. Legal works differently from marketing. | Regulation (EU) 2026/1744 |
| Form | Open. According to the Commission, just asking people to read the instructions for use might not work. | Hands-on workshops on people's own work, with a follow-up session a few weeks later. | European Commission, Q&A |
| Certificate | Not a requirement. You can keep an internal record of trainings and other initiatives. | A certificate of participation for each participant. That gives you part of your record right away. | European Commission, Q&A |
| Measuring knowledge | Not a requirement. | Know per role what people do with AI. | European Commission, Q&A |
| AI officer or fixed governance structure | Not a requirement. | Appoint one person who keeps track of the measures. | European Commission, Q&A |
The points on form, certificate, measuring and an AI officer come from the European Commission's guidance. That guidance is not legal text. The advice column is WAINUT's.
So do you need an AI literacy training?
The law does not prescribe a form. According to the Commission, just asking people to read the instructions for use might not work. Training is therefore a logical measure: your people work faster and more safely with AI and you keep a record of what you did.
The minimum according to the European Commission
- A general understanding of AI
- The role of your organization: do you develop AI yourself or only use it?
- The risk of the AI systems you use
Then you tailor the measures to the role and context of your people.
What we see in practice
The law leaves the form open. An e-learning is then quickly arranged. Our experience is that people work much the same after an e-learning alone. AI literacy grows when people do it themselves, on their own work, with a trainer who watches and corrects. Our trainings are built for that: hands-on workshops with your team's tasks. We always advise a follow-up session a few weeks later.
How to organize AI literacy in five steps
A practical approach in line with article 4 and the minimum the European Commission names.
Map the AI you use
Which AI systems does your organization use or develop, who works with them and what risk comes with them? That determines what your people need to know.
Lay the foundation for everyone
Everyone who works with AI on your behalf gets a general understanding of AI. What can it do and not do, where does it go wrong and how do you use it responsibly?
Tailor it to each role
Take into account the knowledge, experience and training of your people and the context in which they use AI. Also consider the people on whom the AI is used, such as applicants or customers.
Agree on how AI is used
Agree which tools and which data are allowed and who people can turn to with questions. Then everyone knows what is expected.
Record what you did and review it regularly
Keep an overview of trainings, agreements and other measures. AI and the rules change, so update your approach when needed. The law itself changed on 27 July 2026.
How do you show what you did?
According to the European Commission, a certificate is not needed. You can keep an internal record of trainings and other initiatives. Such an overview helps to show what you do.
What to put in your overview
- Who received which training or explanation and when
- Which AI systems you use and who works with them
- Which agreements on AI use apply
- When you review your approach again
Taking an AI literacy training with WAINUT? Then every participant receives a certificate of participation with a personal link. Anyone with the link or the QR code can check on academy.wainut.ai that WAINUT issued it. That gives you part of your overview right away.
Verify a certificate on academy.wainut.ai (opens in a new tab)
When do which rules apply?
The AI Act applies in stages. These are the fixed dates. Since 27 July 2026, the dates for high-risk AI are fixed as well.
- In force
- Still to come
AI literacy and prohibited practices
Article 4 and the prohibitions in article 5 apply. For example, AI that recognizes emotions at work or in education is prohibited, except for medical or safety reasons.
Rules for general-purpose AI models
For models from before that date, the rules apply from 2 August 2027 at the latest.
Article 4 amended
The Digital Omnibus on AI enters into force. A fixed level of AI literacy for each person is no longer required. The dates for high-risk AI are fixed.
General application
From then on the AI Act applies in general, including the transparency rules of article 50. According to the European Commission, supervision by national market surveillance authorities starts then. In the Netherlands, no supervisory authority has been designated yet.
New prohibitions and marking
AI for intimate images of an identifiable person without explicit consent and AI for child sexual abuse material are prohibited. Providers of existing generative systems must then also mark their output.
High-risk AI from annex III
From this date, additional requirements may apply to AI in recruitment and selection, education, credit scoring or decisions on benefits. These include human oversight by people with the necessary competence, training and authority.
High-risk requirements for products
For products from annex I, section A, such as lifts, pressure equipment, personal protective equipment and ATEX equipment. This is mainly a duty of the manufacturer.
Existing systems of public authorities
Final date for existing high-risk AI systems of public authorities.
Who supervises in the Netherlands?
In short: this has not been settled yet. This is the situation on 10 November 2026.
- Supervisory authority
- Not yet designated by law. The Dutch Data Protection Authority (AP) calls itself the intended market surveillance authority.
- Implementation act
- A draft was open for consultation from 20 April to 1 June 2026.
- Planning
- The Dutch government plans to submit it to parliament in the second quarter of 2027. When the act takes effect is still unknown.
- Sanctions for article 4
- The AI Act sets no fine amount for article 4. Member states may set their own sanctions.
According to the European Commission, national market surveillance authorities supervise article 4. The draft Dutch implementation act works with ten market surveillance authorities. The AP and the Dutch Authority for Digital Infrastructure (RDI) coordinate. For article 4, the draft designates the AP, the AFM and DNB. It provides for an enforcement order (last onder bestuursdwang) and no administrative fine. This draft dates from before the Digital Omnibus and may still change.
AI literacy by sector
Article 4 applies in every sector. The difference lies in the AI you use. Some applications may face additional requirements from 2 December 2027.
Government
Public organizations have also had to take measures for the AI literacy of their people since February 2025. If you use AI to decide on benefits or other public services, additional requirements may apply from 2 December 2027, such as a fundamental rights impact assessment.
Education
AI for admission, for assessing learning outcomes or for monitoring during tests may face additional requirements from 2 December 2027. AI that recognizes students' emotions has been prohibited since February 2025, except for medical or safety reasons.
Financial sector
Additional requirements may apply from 2 December 2027 if you use AI for credit scoring of individuals or for risk and pricing of life and health insurance. Fraud detection falls outside this.
Facility services
Recruitment, assigning shifts based on behavior or performance and assessing employees: where AI plays a part in these, additional requirements may apply from 2 December 2027.
Port, energy and industry
The question is whether AI serves as a safety component in the management or supply of gas, heating or electricity. If it does, additional requirements may apply from 2 December 2027.
Construction
Using AI to recruit staff or to manage roads or networks? Additional requirements may apply from 2 December 2027.
What WAINUT does
How WAINUT helps with AI literacy
We train your people on the work they do every day. In the training and the adoption program, we map out what applies to you.
- 1000+professionals trained
Questions about AI literacy
Don't see your question? Call 085 333 2077, email info@wainut.ai or book an intro call.
Is AI literacy mandatory?
Taking measures is mandatory. Since 2 February 2025, article 4 of the AI Act has asked organizations that provide or use AI to take measures for the AI literacy of their people and of others who work with AI on their behalf. Since 27 July 2026, the law states that you do not have to ensure a specific level for each person. Which measures fit depends on your people and how you use AI.
Is AI literacy training mandatory?
The law does not prescribe a fixed form. Taking measures is required. According to the European Commission, just asking people to read the instructions for use might not work. Our experience: an e-learning alone changes little about how people work. Practicing on their own work with guidance does.
Is an AI literacy certificate mandatory?
The law does not ask for a certificate. According to the European Commission, you can keep an internal record of trainings and other initiatives. After a WAINUT AI literacy training, every participant gets a certificate of participation that you can verify on academy.wainut.ai (opens in a new tab). That gives you part of your record right away.
Do you have to measure employees' knowledge?
According to the European Commission, measuring knowledge is not a requirement. Since 27 July 2026, the law also states that you do not have to ensure a specific level for each person. We do advise knowing per role what people do with AI. Then you tailor the training to it.
Do you need an AI officer?
According to the European Commission, an AI officer or a fixed governance structure is not a requirement. We do advise appointing one person who keeps track of the AI literacy measures.
Does AI literacy also apply to government?
Yes. The AI Act also applies to public organizations. Since February 2025, every organization that uses AI has had to take measures for the AI literacy of its people. Since 27 July 2026, a fixed level for each person is not required. If you use AI to decide on benefits or other public services, additional requirements may apply from 2 December 2027, such as a fundamental rights impact assessment.
What happens if you do nothing?
The AI Act sets no fine amount for article 4. Member states may set their own sanctions. In the Netherlands, that law is still being prepared. For article 4, the draft implementation act provides for an enforcement order (last onder bestuursdwang) and no administrative fine. That draft may still change.
Who supervises AI literacy in the Netherlands?
That has not been settled yet. In the Netherlands, no supervisory authority for the AI Act has been designated by law. The Dutch Data Protection Authority is preparing to act as supervisor. The Dutch government plans to submit the implementation act to parliament in the second quarter of 2027.
Sources
This page was updated on . We update it when the law or its explanation changes.
- Regulation (EU) 2024/1689, the AI Act (EUR-Lex) (opens in a new tab)Official Journal, 12 July 2024
- Regulation (EU) 2026/1744, Digital Omnibus on AI (EUR-Lex) (opens in a new tab)In force since 27 July 2026
- European Commission, AI Literacy: Questions & Answers (opens in a new tab)Updated on 20 October 2026
- Dutch Data Protection Authority, AP zet volgende stap in toezicht op AI (in Dutch) (opens in a new tab)9 October 2026
- Dutch Data Protection Authority, Toezicht op AI wordt concreet (in Dutch) (opens in a new tab)20 April 2026
- Government of the Netherlands, Kabinet zet stap met toezicht op Europese AI-regels (in Dutch) (opens in a new tab)20 April 2026
- Draft Dutch AI implementation act, internet consultation (in Dutch) (opens in a new tab)Consultation from 20 April to 1 June 2026
- Parliamentary paper 26643, no. 1554, Digital Affairs planning letter (in Dutch) (opens in a new tab)31 August 2026
Getting started with AI literacy?
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