How to build a role-based AI literacy programme that satisfies Article 4

Article 4 requires AI literacy that takes into account 'the technical knowledge, experience, education, and context in which the AI systems are to be used.' This means a board member overseeing AI governance, a data scientist building models, and a call centre agent using an AI recommendation tool need fundamentally different training.

Generic awareness slides satisfy no one. Worse, if regulators audit your programme and find the same generic content applied to all roles, they may determine that literacy is insufficient — exposing you to Tier 3 penalties (up to €7.5 million / 1.5% of global turnover).

Executive track: AI Act overview, governance responsibilities, liability exposure, risk classification impacts on business decisions, board reporting obligations. Compliance manager track: deep-dive on all applicable obligations, evidence management, audit preparation, interaction with regulators and notified bodies, incident response coordination.

Developer/technical track: system design for compliance, data governance, human oversight implementation, logging and monitoring for regulatory evidence, conformity assessment workflow. End-user/operator track: how to use the specific AI system correctly, understanding limitations and confidence levels, when to override or escalate, incident recognition and reporting path.

Integrate AI literacy into onboarding for every new hire whose role touches AI. Schedule annual refreshers with ad-hoc updates when new AI systems are deployed or regulations change. Maintain records of completion dates, assessment scores, and training content versions — this is the audit evidence regulators expect.

ActLoom's campaign builder provides pre-built modules for each track, with completion tracking and exportable evidence reports ready for regulatory requests.