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AI Act literacy takes center stage in the latest regulatory update, as the European Commission has published a dedicated Questions and Answers clarifying the literacy requirements under Article 4 of the AI Act which are already applicable from 2 February 2025.
This new guidance confirms what legal and compliance professionals suspected: meeting the AI Act’s obligations means going far beyond generic training modules—it requires a structured, risk-based governance approach to the use of AI across organizations.
The Key Takeaways from the Q&As on AI Act Literacy
The FAQs break down how organizations must approach AI literacy. It’s no longer sufficient to host an annual awareness session. Instead, the AI Act demands tailored, ongoing initiatives that reflect the real-world responsibilities and risks associated with each role interacting with AI systems.
Here’s what the European Commission outlines:
1️⃣ AI literacy means capability—not just awareness. Staff must understand, use, and evaluate AI systems responsibly, including their limitations and potential harms.
2️⃣ Training must be role-specific. Developers, users, and deployers each require different levels and types of AI education, aligned with their technical and business responsibilities.
3️⃣ AI literacy applies to external actors, including third-party service providers and contractors, not just internal teams.
4️⃣ The obligation under Article 4 applies even in non-high-risk AI scenarios if the system affects people’s rights, safety, or essential services.
5️⃣ Organizations must assess knowledge, responsibilities, and risk exposure—not just deliver a one-size-fits-all course.
AI Act Literacy Means Governance, Not Just Compliance
The FAQs make it clear: AI Act literacy is a cornerstone of AI governance, not a stand-alone initiative. To comply, organizations need to embed literacy into a wider organizational model, which includes:
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📌 Internal governance rules for the design, deployment, and oversight of AI systems
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📌 Policies and procedures aligned with the AI Act’s risk classification (e.g., minimal, limited, high risk)
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📌 Continuous improvement processes ensuring systems remain explainable, transparent, and aligned with ethical and legal standards
In other words, training is only the starting point. Organizations need to create a culture of accountability and informed AI usage, involving all stakeholders across the AI lifecycle.
Why AI Act Literacy Should Be a Priority Now
The publication of the FAQ sends a strong message: AI Act literacy is not a box to tick—it’s a legal requirement with real operational consequences. Regulators will expect evidence of structured training, clarity on who was trained and how, and documented policies ensuring that literacy is part of the organization’s AI risk management framework.
To respond effectively, businesses should:
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✅ Conduct a literacy and risk assessment across all AI-related functions
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✅ Develop role-specific training plans supported by legal, compliance, and technical leadership
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✅ Establish a central oversight function (such as a Chief AI Officer or AI Compliance Officer) to manage literacy and governance efforts
Final Thoughts
AI Act literacy is more than a regulatory buzzword—it’s a call to action for organizations across the EU and beyond. With the European Commission’s FAQs now in place, companies must rethink how they train, govern, and manage their AI systems.
Failure to embed AI literacy into a structured governance model will not only put organizations at compliance risk—it could expose them to reputational damage, user distrust, and operational inefficiencies. Read this article to know our recommendations on how to structure AI Governance “Is Your Organization Ready for AI Governance?“.
On the topic, you can also find our AI Law Journal interesting, click HERE to see the latest issues.