AI literacy is now enforceable: what employers must teach their staff - Publications

Aleksandra Auleytner explains employers’ obligations regarding AI literacy under the EU AI Act in an article published in BPCC Contact Magazine Online.

Since 2 February 2025, every organisation that provides or deploys an AI system in the EU has operated under a duty most have barely noticed: making sure the people who touch that system understand it. Article 4 of the AI Act requires providers and deployers to “take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf”. That is not aspirational. National market surveillance authorities began supervising and enforcing it from 2 August 2026, and the obligation itself has already been in force for well over a year.

What changed, and why the headline still holds

The picture became more complicated in mid-2026. The Digital Omnibus on AI, Regulation (EU) 2026/1744, amended Article 4 as part of a wider simplification of the AI Act. Previously, Article 4 required a ‘sufficient’ level of AI literacy among staff; the Commission’s own recitals acknowledged that this blanket, unqualified standard had proven difficult to apply. The amended text keeps the obligation but drops “sufficient”: organisations must still take measures to support AI literacy, but the law no longer sets a specific bar, and need not guarantee any particular level of literacy for any individual employee.

That is a real softening, but it does not make the duty optional, nor does it touch enforcement. The Commission’s AI Office FAQ is explicit that Article 4 “remains an obligation for providers and deployers”, applicable since 2 February 2025, with supervision and enforcement resting on national market surveillance authorities from 2 August 2026, not the AI Office itself. AI literacy is enforceable law today, administered nationally, against a softer standard than originally drafted.

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The full article by Aleksandra Auleytner, Partner and Head of the IP&TMT Practice, is available in English in the latest edition of Contact Magazine Online, published by the British Polish Chamber of Commerce (BPCC).