AI literacy · AI Act Article 4
AI literacy training, the way the AI Act intends it
Since 2 February 2025, the AI Act has asked organizations that use AI to work on the AI literacy of their people. On this page you can read exactly what that means, what changed in July 2026, who supervises it and how you demonstrate it. And how we fill it in per role: practical, on your own tools.
- Applies to SMEs too
- No certificate required
- Keynote € 2,450 · workshop € 4,500
2025
Article 4 of the AI Act has applied since 2 February
2026
A new text since 27 July: taking measures
0
Certificates required. Do record what you did
4
Steps in the guidance from the Dutch Data Protection Authority
01 / What the law asks
What does Article 4 of the AI Act ask?
Article 4 asks organizations that make or use AI systems to take measures for the AI literacy of their staff and of others who work with AI on their behalf. You tailor those measures to people's knowledge, experience and training and to the context in which the AI is used. It has applied since 2 February 2025.
The AI Act (Regulation (EU) 2024/1689) names two roles. The provider makes an AI system or places it on the market, such as OpenAI, Microsoft or Anthropic. The deployer uses an AI system under its own authority. If you use ChatGPT, Copilot, Claude or an AI feature in your accounting package, you're a deployer. Article 4 applies to both.
AI literacy is broader than 'knowing how to prompt'. It's about the knowledge and skills to use AI consciously and responsibly: what it can do, what it can't do, where the risks are and what it means for the people it concerns.
Article 4 makes no exception for SMEs. A twelve-person business that uses Copilot falls under it just as much as a multinational. You may set it up proportionately, though: a small team with one tool needs a different plan than an organization that uses AI in hiring.
01Applies to
Providers and deployers of AI systems. So also if you 'only' use ChatGPT or Copilot.
02Covers
Your staff, but also contractors and service providers who work with AI on your behalf.
03How far it goes
Proportionate: tailored to knowledge, experience, the context and the risk of what you do with AI.
04Since when
2 February 2025. In July 2026 the text was amended; the obligation remained.
02 / What changed
What changed in July 2026?
On 27 July 2026, the Digital Omnibus on AI entered into force (Regulation (EU) 2026/1744). It rewrote Article 4. The obligation remained, but it's worded differently: you take measures that support AI literacy, and you don't have to guarantee that every employee reaches a certain level.
| Until 27 July 2026 | Since 27 July 2026 | |
|---|---|---|
| Core of the obligation | Measures to ensure, as far as possible, a sufficient level of AI literacy | Taking measures that support the development of AI literacy |
| Who it applies to | Providers and deployers | Unchanged |
| Tailored to knowledge, experience, training and context | ✓ | ✓ |
| Guaranteeing a certain level per person | Not explicitly addressed | Expressly not required |
| Help from the Commission and member states for smaller organizations | · | ✓ |
| Certificate required | · | · |
Sources: Regulation (EU) 2024/1689, Article 4; Regulation (EU) 2026/1744 (Official Journal, July 2026); European Commission, questions and answers on AI literacy (2025). Summary in plain language, not legal advice. If you want to know exactly what this means for your organization, consult a lawyer.
03 / Supervision
Who supervises AI literacy in the Netherlands?
Supervision of the AI Act lies with national market surveillance authorities. According to the European Commission, their supervision and enforcement of AI literacy applies from August 2026. In the Netherlands, the Uitvoeringswet AI-verordening, the Dutch act implementing the AI Act, is to arrange that. It was open for online public consultation from 20 April up to and including 1 June 2026 and had not yet been adopted in October 2026.
In that bill, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, AP) and the Dutch Authority for Digital Infrastructure (Rijksinspectie Digitale Infrastructuur, RDI) become the coordinating supervisory authorities. The AP is the intended supervisor for AI literacy; for financial institutions, that's the AFM and DNB.
Can you get a fine?
Article 99 of the AI Act doesn't set a separate fine amount for Article 4; it leaves penalties to the member states' own laws. The Dutch draft opts for remedying the situation: the supervisor issues an instruction with a deadline, and only after that can an order subject to a penalty payment (last onder dwangsom) follow. So according to the draft, no direct fine, but the draft may still change. Don't wait for it either: the obligation itself already applies, and rules such as the GDPR simply apply alongside the AI Act.
What the AP is already saying
The AP has published two guidance documents: Aan de slag met AI-geletterdheid (Getting started with AI literacy, 2025) and Verder bouwen aan AI-geletterdheid (Building further on AI literacy, October 2025). The core is a cycle of four steps that you keep repeating. Below you can read how we fill them in.
01Dutch Data Protection Authority
Intended supervisor for AI literacy, and together with the RDI a coordinating supervisory authority.
02RDI
Coordinating supervisory authority and central point of contact for Europe.
03AFM and DNB
For financial institutions.
04Status
The Uitvoeringswet AI-verordening had not yet been adopted in October 2026. Check the current status with the Dutch government (Rijksoverheid).
04 / What it includes
What should an AI literacy program include at a minimum?
The law doesn't prescribe a curriculum. In its questions and answers (2025), the European Commission does name four things to include at a minimum. We build every training around them.
01
Understanding AI
What AI is, how it works, what it does well and where it goes wrong. Without jargon.
02
Your role
Are you a provider or a deployer? For most organizations, the second.
03
The risks of your systems
Not AI in general, but the tools you use, and what for.
04
Tailored to the people
What someone needs to know depends on role, experience and what's at stake.
05 / How to approach it
In four steps, as the AP describes it.
The AP's guidance describes a cycle of four steps that you keep repeating. As preconditions, the AP names among other things management involvement, budget, clear responsibilities and periodic monitoring. This is how we fill in the steps.
- 01
Identify
Week 1
Which AI systems do you use, who works with them and what for? A simple list is enough to start. Don't forget the AI features in existing software.
- 02
Set the goal
Per role
What does everyone need to know, what do daily users need to be able to do, and what about the people who build or decide? The higher the risk, the deeper it goes.
- 03
Carry it out
Keynote and workshops
A keynote for the whole organization, hands-on workshops per team on your own tools, and clear ground rules in an AI policy.
- 04
Evaluate
Every year or with a new tool
Is it working, are people using it well, and what has changed? Record what you did and plan the next round.
06 / By role
How NinA fills in AI literacy per role.
A recruiter who uses AI to select CVs needs something different from a colleague who has their email summarized. That's why we work per role. This is what it usually looks like.
| Everyone | Daily users | Builders and advanced users | Leadership and management | |
|---|---|---|---|---|
| What they need to know | What AI is, what it isn't, and what can't go in | Good prompting, checking output, working safely with data | How workflows and agents work, testing, limits and the human in the loop | Opportunities, risks, your role under the AI Act and the AI policy |
| Format | Keynote | Hands-on workshop per team | Advanced workshop or training in the partnership | Workshop for the management team, or the AI Quick Scan |
| Price | € 2,450 | € 4,500 per half day | € 4,500 per half day, or from the partnership hours | € 4,500 per half day, or € 6,000 for the Quick Scan |
| What you record | Date, participants and topics | Plus the tools and ground rules covered | Plus which systems they build or manage | Plus the AI policy and who is responsible for what |
| Repeat | With new policy or new tools | Every year or with a new tool | Ongoing | Every year |
Swipe sideways to see all columns →
All amounts excl. VAT, travel within the Netherlands included. Workshops for 6 to 15 participants, about 3 to 4 hours.
07 / How you demonstrate it
How do you demonstrate AI literacy?
With simple, honest record-keeping. A certificate isn't needed, the European Commission writes. Internal records of training and other measures are sufficient. What you want to be able to show:
- A list of the AI systems you use, and what for
- Per role what people need to know, and why
- Who had which training, when, and on which tools
- Your AI policy: what's allowed, what isn't, and where a human checks
- When you'll review it again
That fits on a few pages. Start with the AI policy. If you want to know what else the AI Act means for you, read What the AI Act means for your business.
An e-learning that everyone clicks through is also a measure. But a team that really knows what it's doing is better for your business. And for your customers.
08 / Try it yourself
Where does a human belong? That's where AI literacy starts.
An AI-literate team knows for every task which role AI gets: does it help, does a human approve, or does AI do it by itself? Pick a task and see where it lands. We practise choices like these in every workshop.
Pick a task
Human
A person does the work. AI stays out.
AI assists
A person does it, AI drafts or looks things up.
Human approves
AI does the work, a person checks before it goes out.
Fully AI
AI does it by itself. A person spot-checks.
Where it lands: Human approves
AI prepares the answer with the right order details. An employee reads along and sends: tone and exceptions stay human.
You could feel the energy. Our whole team walked out with concrete ideas that we started using that same week.
Our starting point
AI literacy is not a box to tick. It's a team that knows what it's doing.
That's why we train on the tools you actually use, with your own work, and finish with agreements people understand. The evidence for the AI Act then follows naturally. Don't let it drive you crazy. Start small.
09 / Questions
Frequently asked questions about AI literacy.
This is an explanation in plain language, not legal advice. If you're unsure about your situation, bring in a lawyer.
Is AI literacy mandatory?
Yes. Article 4 of the AI Act obliges organizations that make or use AI systems to take measures for the AI literacy of their staff and others who work with AI on their behalf. That has applied since 2 February 2025. Since 27 July 2026 (Regulation (EU) 2026/1744), the text has been worded differently: you take measures, but don't have to guarantee a level per person. If you're unsure what this means for you, consult a lawyer.
Since when has the AI literacy obligation applied?
Since 2 February 2025, at the same time as the prohibition on certain AI applications. On 27 July 2026, the Digital Omnibus entered into force (Regulation (EU) 2026/1744), which amended the text of Article 4. The obligation remained.
Does AI literacy apply to SMEs too?
Yes. Article 4 makes no exception for small businesses. If your team uses ChatGPT, Copilot, Claude or AI in other software, your organization falls under it. You may set it up proportionately: a small team with one tool needs a simpler plan than an organization that uses AI in hiring or credit decisions.
Who supervises AI literacy in the Netherlands?
Under the bill for the Uitvoeringswet AI-verordening, the Dutch Data Protection Authority becomes the supervisor for AI literacy, with the AFM and DNB for financial institutions. The AP and the RDI become coordinating supervisory authorities. That act had not yet been adopted in October 2026.
Can you get a fine if you do nothing about AI literacy?
The AI Act itself doesn't set a fine amount for Article 4; the member states arrange penalties. The Dutch draft of the implementation act opts for corrective sanctions: first an instruction with a deadline, then possibly an order subject to a penalty payment. That may still change in the legislative process. Don't wait for it: the obligation itself has applied since February 2025. For an assessment of your situation, consult a lawyer.
Do you need a certificate for AI literacy?
No. According to the European Commission, a certificate isn't mandatory and internal records of training and other measures are sufficient. Record which AI systems you use, who had which training and when, and what your AI policy is.
Does it also apply to contractors and temporary workers?
Yes. Article 4 covers your staff and others who use AI systems on your behalf. The European Commission expressly mentions contractors and service providers. So include them in your plan, or make agreements with their employer.
Is one e-learning module enough?
It counts as a measure, but it's thin if it's the same module for everyone. The law asks you to tailor it to knowledge, experience and context. A recruiter who uses AI in selection needs more than someone who has their email summarized. So combine a foundation for everyone with more depth per role.
What does AI literacy training at NinA cost?
A keynote for the whole organization costs € 2,450 and a hands-on workshop per team € 4,500 per half day, excluding VAT and including travel within the Netherlands. Within the AI Partnership, workshops are built in. We tailor the content to the roles and tools in your organization.
Do you give legal advice on the AI Act?
No. We explain what the AI Act asks and help set it up in practice: training, ground rules and an overview of your AI use. For a legal assessment of your specific situation, we refer you to a lawyer.
Further reading
- What the AI Act means for your businessRisk categories, obligations, the timeline and a checklist for SMEs.
- AI training for employeesKeynote, workshop or training in the partnership: all formats side by side.
- Using AI safelyFive risks and what to arrange, from data leaks to shadow AI.
- Writing an AI policyWhat goes in it, an example structure you can copy and the role of AI literacy.
Arrange AI literacy without drowning in paperwork
In fifteen minutes, we map out which roles and tools you have, and which combination of keynote and workshops fits.
01
Intro call
Fifteen minutes, no strings. Where does work get stuck and what do you want to achieve?
02
AI Quick Scan
One day on site. Within a week, a business case and a roadmap.
03
AI Partnership
A dedicated team that builds, trains and shows what it delivers every month.
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