AI Training for Employees: A Legal Requirement Under the EU AI Act

The era where AI training was a 'nice to have' is over. With the enforcement of the EU AI Act, training employees who work with AI has become a legal obligation. For HR managers, L&D professionals, and executive boards, this means taking action. In this blog, we explain exactly what the law requires, who it applies to, and how your organization can get started.

What does the EU AI Act require?

Article 4 of the EU AI Act obliges both providers and deployers of AI systems to ensure that their staff possess sufficient AI literacy. Note: this does not only apply to organizations developing AI software. Companies that purchase AI tools and use them internally also fall under this scope. Does your organization use Microsoft Copilot, ChatGPT, an AI-driven chatbot, or other AI applications? Then this obligation applies to you.

The legislator does not prescribe a specific form of coursework but does require organizations to actively increase the knowledge level of employees. Legal experts interpret this as a factual training obligation. It is not a matter of simply sending around a PDF and hoping everyone reads it. You are expected to be able to demonstrate that employees have actually been trained.

To whom does the obligation apply?

The short answer: almost everyone who works with AI. The law makes no distinction between IT specialists and other employees. Anyone who operates AI systems, configures them, or makes decisions based on AI output falls under the obligation. Examples include:

• The customer service representative managing an AI chatbot
• The marketer generating content with AI tools
• The financial analyst creating reports using Copilot
• The HR advisor screening CVs with AI support
• The manager steering based on AI-generated dashboards

Furthermore, the obligation extends to external parties working with AI systems on behalf of your organization. Are there hired consultants, freelancers, or service providers with access to your AI tools? They too must be sufficiently AI literate.

Even for low-risk applications

A common misconception is that the AI Act only applies to high-risk systems. That is incorrect. Even for low-risk applications such as chatbots or text generators, the knowledge level of users must be appropriate to the risk of the system. The bar may be lower than for medical AI or credit scoring systems, but there is a bar.

What should the training include?

The EU AI Act requires that the content and depth of training align with the employee's role, their technical background, and the concrete use case. A one-size-fits-all e-learning is therefore insufficient. The training should, at minimum, contain the following elements:

• Basic AI mechanics: How do AI systems work? What can they and can't they do? Where are the limitations and risks of errors?
• Risks and ethical boundaries: What risks are associated with AI use? Think of bias, hallucinations, privacy violations, and over-reliance on AI output.
• Legal frameworks: What does the AI Act say? How does AI use relate to privacy legislation such as the GDPR? Where do liabilities lie?
• Safe daily use: How do you use AI tools responsibly? What information are you allowed and not allowed to input? How do you verify AI output?

For technical teams building or managing AI systems, additional requirements apply regarding architecture, security, and compliance.

Why documentation is crucial

In the event of an audit, you must be able to prove that employees have been trained. Experts therefore advise making training demonstrable with documentation and certificates. Maintain a compliance file in which you record:

• Which employees have followed which training
• When the training was completed
• Which topics were covered
• How the training aligns with the employee's role

Organizations that fail to do this risk enforcement measures and reputational damage. The Data Protection Authority and other regulators can impose fines for non-compliance.

The urgency is now

The AI literacy obligation is one of the first parts of the AI Act to come into force. Waiting is no longer an option. At the same time, we see that many organizations are still searching: What exactly do we need to do? How do we roll this out to hundreds or thousands of employees? How do we ensure the training aligns with different roles?

How The AI Group helps

At ai.nl, we support organizations in meeting the AI literacy obligation. Our training offering is modularly structured and aligns with various roles and knowledge levels:

• E-learning AI Agents: Scalable and flexible, including tracking and certification for your compliance file.
• Training AI Literacy: The mandatory foundation for every employee. Understandable, practical, and directly applicable.
• Workshop AI Deep Dive: For teams that use AI intensively. Hands-on sessions on-site or online.
• Technical skills: Multi-Agent Systems: For developers and IT teams building and managing AI systems.

We are happy to collaborate on a training plan that fits your organization. Contact us for a non-binding consultation.

Getting started with AI yourself? View our AI keynote or AI consultancy.

// About the author

Remy Gieling

Mede-oprichter, AI-expert & bestseller-auteur

Tech-expert (1988) gespecialiseerd in kunstmatige intelligentie en mede-oprichter van ai.nl, The Automation Group, Proxies en eBrain.ai. Oud-hoofdredacteur van diverse zakenmerken en daardoor een geoefend verteller op het podium en in de media. Verzorgt jaarlijks 150+ AI-keynotes in binnen- en buitenland en is gastdocent aan Nyenrode. Co-auteur van zeven boeken, waaronder 'Handboek AI Strategie' en 'AI Agents', en bekend als presentator op radio en RTL Z. Reist langs de labs van OpenAI, Nvidia en Tencent en vertaalt de nieuwste doorbraken naar inzichten die leiders direct kunnen toepassen.

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