AI literacy obligation: from which date does it apply?

The short version: the AI literacy obligation has applied since 2 February 2025. From that date, providers and deployers of AI systems must take measures to ensure their staff have a sufficient level of AI literacy. This follows from Article 4 of the EU AI Act (Regulation (EU) 2024/1689).

What exactly does the law say?

Article 4 phrases the obligation as follows:

"Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf."

Note the wording: the law asks for measures to ensure, to their best extent, a sufficient level. It is not an obligation to obtain a specific certificate or follow a fixed curriculum — it is an obligation to demonstrably do something, appropriate to the role, the context and the risks of the AI systems in use.

Is there a fine for Article 4?

No — there is no standalone fine for failing to ensure AI literacy under Article 4. The fine regime of Article 99 — up to €35 million / 7% (prohibited practices under Article 5), up to €15 million / 3% (other operator obligations) and up to €7.5 million / 1% (incorrect information) — does not include a dedicated tier for Article 4. Market-surveillance authorities may, however, treat an absent or inadequate AI literacy programme as an aggravating factor when assessing related violations.

Who supervises this in the Netherlands?

In the Netherlands, the Dutch Data Protection Authority (AP) is a central supervisor of the AI Act. The AP describes AI literacy as a continuous four-step cycle: identify, set goals, execute and evaluate. The Dutch supervisory model is hybrid and built on multiple authorities; the precise allocation depends on the sector and the AI system and is, at the time of writing, still the subject of legislation in public consultation.

How do you get started?

Use the AP's four-step plan as your framework:

1. Identify which AI systems your organisation uses and who works with them.
2. Set goals for the desired level of AI literacy per role.
3. Execute: provide training appropriate to role, context and risk.
4. Evaluate and repeat — AI literacy is not a one-off exercise.

Want to make this demonstrable for an audit? Start with an AI register and a role-based training track, and record the results.