EU Commission Publishes Q&A on AI Literacy

On May 7, 2025, the European Commission published a Q&A clarifying the AI literacy obligation under Article 4 of the AI Act. This follows earlier guidance provided in a February 2025 webinar. The Q&A confirms that the obligation to ensure AI literacy among staff applies from February 2, 2025, but enforcement by national market surveillance authorities will only commence from August 3, 2026.

The AI literacy requirements apply broadly to all providers and deployers of AI systems within the EU. Organizations must train anyone directly interacting with AI systems, including employees, contractors, and service providers. The Commission emphasizes that relying solely on instructions for use or user manuals is insufficient to meet the obligation.

While there is flexibility in designing AI literacy programs, the Commission expects organizations to ensure a general understanding of AI, tailor training to the organization’s role as provider or deployer, and consider the risk profile of the AI systems in use. Programs should be adapted to staff technical capabilities and the specific context of AI usage. Internal records of training initiatives are considered adequate evidence of compliance; issuing certificates is not mandatory.

National market surveillance authorities will oversee compliance, with Member States required to appoint these authorities by August 2, 2025. The Q&A highlights that organizations deploying generative AI for tasks such as content creation or translation must inform staff about specific risks, including hallucination. Compliance with these requirements is essential to avoid regulatory scrutiny once enforcement begins.