The European Commission’s AI Office gave some early indications on what organisations developing and using AI systems should do to comply with the upcoming AI literacy obligation while preparing formal guidance.

The EU’s AI Act mandates that AI developers and users should take measures to ensure that relevant staff have a “sufficient level of AI literacy” taking into account the context and people potentially affected by the AI system in use.

Broad scope

This obligation, detailed in Article 4, is extremely broad as it concerns everyone developing or using an AI system regardless of the level of risk of their use case, including systems that don’t have a specific purpose like OpenAI’s ChatGPT and Microsoft Copilot. Moreover, the requirement covers not only the staff that directly deals with an AI system but also the persons operating an AI system on behalf of the organisation, such as an external contractor or a service provider.

In the EU AI Act the notion of “AI literacy” is defined as having the skills, knowledge, and understanding “to make an informed deployment of AI systems” and be aware of the opportunities and risks associated with AI.

The main question mark organisations are likely to face is defining a “sufficient level” of literacy and also what is considered "to their best extend".

Clarifications

In exchanges with companies in the past weeks, the AI Office has clarified what are its expectations in terms of compliance. The AI Office has been engaging on this topic with participants in the AI Pact, an initiative for companies that want to commit to implementing early parts of the AI Act’s duties. In these preliminary exchanges, the AI Office said that this requirement entails providing training and guidance.

In other words, organisations won’t be in compliance simply by mandating employees to read the AI system’s written instructions. Rather, they will have to actively promote the relevant skills and knowledge among their staff members.

Formally, the AI literacy obligation will take effect on February 2. However, enforcement by competent national authorities will not begin until August 2, aligning with the timeline for implementing the AI Act’s bans on unacceptable use cases. This interim period provides organisations with a valuable opportunity to design and implement robust AI literacy programs. It also allows time to identify and collaborate with expert partners to ensure their teams are well-prepared and compliant with the upcoming requirements.

Despite this grace period, due to a lack of national enforcers, the AI Office expects that, as of February, organisations at least ensure a general understanding among staffers of what the AI Act entails. At a later stage, they will have to upgrade their AI literacy measures proportionally to how each employee uses AI, the employee's role in the organisation and the risk associated with the AI system. However, the AI Act’s requirements for high-risk AI systems will only enter into force next year, meaning that the compliance posture of many companies is not yet mature in mapping and classifying their AI uses.

Use Free Resources

Digital Bricks is hosting a webinar on January 29 to provide you with actionable insights into the EU AI Act, with a specific focus on AI literacy. This session is designed to help organisations proactively prepare for February 2 by mapping out effective AI literacy programs strategies and tackling role-specific training needs. The webinar will explore how compliance can be transformed from a regulatory chore into a business value driver, enabling organisations to stay ahead of the curve

On February 20, the AI Office is organising a public webinar focused on AI literacy, where they plan to unveil a repository of best practices collected through their AI Pact initiative. This repository will include real-world literacy practices, such as organizing role-specific training, participating in seminars, partnering with academic institutions, and utilizing online learning resources. The AI Office aims to not only cultivate a culture of AI literacy within organizations but also promote advanced AI-related skills in strategic sectors as part of the forthcoming Apply AI strategy.

By leveraging free resources like these webinars and shared best practices, organizations can proactively enhance their AI literacy, ensuring compliance while driving meaningful business outcomes.

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