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AI literacy and the AI Act: what do you need to do as an employer?

Since February 2025, every organisation that uses AI must ensure AI literacy. Here is how to approach it in five steps.
15 - 09 - 2026

If your organisation uses AI, you need to support the AI literacy of your people. Article 4 of the European AI Act has required this since 2 February 2025, even if you only use Microsoft Copilot or ChatGPT.

What does AI literacy mean under the AI Act?

The AI Act describes AI literacy as the knowledge and skills to use AI consciously, with an eye for opportunities and risks.

The law does not require you to organise an exam or hand out certificates. You do need to be able to show that you take measures that fit the role of your people and the AI applications they use.

Who does the obligation apply to?

The AI Act applies to every organisation that develops or uses AI within the EU.

An employee who summarises a report with Copilot already falls under it. An HR team that uses AI in recruitment needs more than a general introduction.

How do you approach it in five steps?

  1. Map which AI is in use. Employees often use more tools than IT knows. With Xylos Insights, an AI agent has short conversations with every employee and you see per team which applications are already in use.

  2. Measure the level per role. A business analyst has different needs than an operator. Set a target level for each role and compare it with the current level.

  3. Record agreements in an AI policy. Employees need to know what is allowed. A short AI policy with concrete examples works better than a long document.

  4. Build a tailored learning path. Combine microlearning with hands-on workshops and coaching on the work floor. Our AI literacy programme follows that structure.

  5. Measure again and document. A second measurement shows you the progress and gives you proof that your approach works.

How do you show that you comply?

Keep track of who followed which training, which guidelines apply within your organisation and how the level of your people evolves.

A first and a repeated measurement per team give you clarity. At Maxeda, such a measurement ran in the second phase of their AI literacy programme. We surveyed 550 people in the first two conversations.

How does Xylos help?

Xylos combines 40 years of experience with learning paths and its own AI scan. Organisations such as Atlas Copco, ENGIE, UCB and KBC rely on Xylos for their learning paths. We map the knowledge level per role. Then we draw up the learning path and measure progress.

Also read how to set up AI and Microsoft 365 training for employees, or discover the full Learning Services offering.