AI Literacy, Let's Get to Work

Published on Feb 27, 2025

Since the rise of ChatGPT and other forms of generative AI, AI has been used in the execution of work in almost all companies. If that applies to your company, there is work to be done. The EU’s AI Act stipulates that if your company uses an AI system, you are responsible for AI literacy among employees, management, and contractors at your company as of February 2, 2025. The following article explains what this means and how your company can fulfill this obligation. 

Crucially, in our view, AI literacy should not be limited to people working with AI systems. If you are going to roll out a literacy plan, independently or together with your works council, make sure everyone at your company is included.

The AI Act does not provide a timetable describing the steps for implementing AI literacy. This can be seen as an advantage. Companies, for example, enjoy some flexibility in fulfilling this obligation within the framework of the AI Act.  In general terms, the AI Act requires that companies ensure the following:

  • That employees and others using AI systems on your behalf have an adequate level of AI literacy, taking into account:
    • the technical knowledge of these persons, experience, education, and training;
    • the context in which the AI systems will be used; and
    • the persons or groups of persons assigned to use the AI systems.
  • That any training given relates to the risks of using AI systems and the damage it can cause. 

Steps towards AI literacy

To obtain AI literacy, companies should do the following:

  • Determine the training needed to achieve AI literacy by first mapping out all AI systems in use, identifying the risks embedded in these systems, and assessing their possible impact. Companies should immediately consider the risk category a specific system falls under.
  • Make a baseline measurement of the general knowledge and skills within your company. Training courses and questionnaires can be used to determine the state of knowledge of AI and its use.
  • After taking inventory, set learning objectives for each position and assess how much working time should be allocated for this. Customization is always needed since some people may need more and different training on AI systems than others. For each position and person, you assess what is needed, considering both the individual and the position. 
  • Involve your works council. Introducing staff training requires prior consent. In practice, some employers have been actively involving their works council, whether or not through AI-process agreements, in the rollout of AI literacy and AI implementation at the company. The AI Act stipulates that in certain cases, companies must inform and involve works councils in the deployment of AI systems. 
  • Remind employees that they are expected to make an effort to gain the necessary training since AI literacy falls within the statutory training obligations of an employer. Companies should determine the specific knowledge that must be acquired, how to impart this knowledge, and the time frame for training. Companies should regularly test employees to measure knowledge levels.

To read more about AI training services at CMS, visit here our AI page.

To discuss AI literacy and other obligations mandated by the AI Act, contact your CMS client partner or these CMS experts.