The EU wrote AI literacy into law and rewrote the duty this summer. Where that leaves a UK employer, and what three public sources offer on what a course for your staff should cover.
Is AI Literacy Training Required in the UK? The Law, and What Training Should Cover
By James Cotton · Last updated · 9 min read
Part of our topic guides on AI Skills for Business and AI Governance & Data Strategy.
By James Cotton, Founder, iO-Sphere
Is AI literacy training a legal requirement in the UK?
On 2 October 2026 we searched the full text of all UK primary and secondary legislation on legislation.gov.uk, Westminster and devolved, for "AI literacy", "artificial intelligence literacy" and "AI training". Each search returned no results. A wider search for "artificial intelligence" in legislation from 2023 to 2026 returned 11 Acts and 6 instruments, none placing an AI training duty on employers. We found no UK law requiring AI literacy training.
General training duties already sit in UK law, and they can apply to the use of an AI tool where it creates the risk they address. Section 2(2)(c) of the Health and Safety at Work etc. Act 1974 requires an employer to provide "such information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of his employees".
Sector rules can also reach AI use. For the firms it regulates, the Financial Conduct Authority states in AI and the FCA: our approach: "We do not plan to introduce extra regulations for AI. Instead, we'll rely on existing frameworks, which mitigate many of the risks associated with AI."
When does the EU AI Act reach a UK business?
The test is in the Act's scope article. These are points (a) to (c) of Article 2(1) of Regulation (EU) 2024/1689, unchanged by the 2026 amendments. The Regulation applies to:
(a) providers placing on the market or putting into service AI systems or placing on the market general-purpose AI models in the Union, irrespective of whether those providers are established or located within the Union or in a third country;
(b) deployers of AI systems that have their place of establishment or are located within the Union;
(c) providers and deployers of AI systems that have their place of establishment or are located in a third country, where the output produced by the AI system is used in the Union;
A business using a bought-in AI tool at work is a deployer, which Article 3(4) defines as a person or body "using an AI system under its authority except where the AI system is used in the course of a personal non-professional activity". For a UK employer that only uses bought-in tools and is neither established nor located in the EU, the question is point (c).
Point (c) turns on one thing: whether the output produced by the AI system is used in the Union. On our reading, that depends on where the work made with the tool is put to use. A business with its own place of establishment in the EU should also read point (b) against its set-up.
What Article 4 says now
For a business inside the Act, Article 4 has applied since 2 February 2025. It was replaced by Regulation (EU) 2026/1744, and the new text has applied since 27 July 2026. Its first paragraph now reads:
Providers and deployers of AI systems shall take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be used.
This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual.
The original wording required measures "to ensure, to their best extent, a sufficient level of AI literacy". The amendment kept the obligation and changed its standard. Recital 8 of the amending Regulation gives the EU legislator's reasons and adds that "AI literacy should be a strategic priority, regardless of regulatory obligations and potential sanctions".
The European Commission's AI literacy questions and answers say the duty "concerns anyone in the organisation directly dealing with an AI system". The "other persons" in Article 4, the Commission says, "are not employees, but persons broadly under the organisational remit. It could be, for example, a contractor, a service provider, a client."
The Act sets a separate requirement for deployers of high-risk AI systems, untouched by the 2026 amendments. Article 26(2) says: "Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support." Which systems count as high-risk, and from when, is in our guide to AI regulation in the UK in 2026.
The European Commission says national market surveillance authorities start supervising and enforcing from August 2026.
What does "AI literacy" mean?
The legal definition is in Article 3(56) of the EU AI Act, which the 2026 amendments left as it was. We found no UK statute or regulator that defines it as a legal term.
'AI literacy' means skills, knowledge and understanding that allow providers, deployers and affected persons, taking into account their respective rights and obligations in the context of this Regulation, to make an informed deployment of AI systems, as well as to gain awareness about the opportunities and risks of AI and possible harm it can cause
The definition names three groups, but the Article 4 duty does not extend to affected persons.
Skills England's annual skills report 2026 described "practical AI literacy" as "the ability to use, verify and safely integrate AI tools", and said 2025 research showed most workers would need it, "while a smaller share will need specialist technical skills".
What should AI literacy training cover?
The Commission's points to consider
The Commission's guidance says providers and deployers "should consider at least the following steps and questions":
- a) "Ensure a general understanding of AI within their organisation: What is AI? How does it work? What AI is used in our organisation? What are its opportunities and dangers?"
- b) "Consider the role of their organisation (provider or deployer of AI systems): Is my organisation developing AI systems or just using AI systems developed by another organisation?"
- c) "Consider the risk of the AI systems provided or deployed: What do employees need to know when dealing with such AI system? What are the risks they need to be aware of and do they need to be aware of mitigation?"
- d) "Concretely build their AI literacy actions on the preceding analysis, considering differences in technical knowledge, experience, education and training of the staff and other persons ... as well as the context the AI systems are to be used in and the persons on whom the AI systems are to be used"
Because these "include legal and ethical aspects", it says "connections to the EU AI regulation (i.e., understanding of the AI Act) and to principles of ethics and governance are encouraged." For the governance side, see what AI governance is. The same guidance says "no strict requirements or mandatory trainings are imposed".
Skills England's six AI foundation skills for work
Skills England published its AI foundation skills for work benchmark for England on 28 January 2026. It set out "the basic skills people need to use simple AI tools at work", on the premise that people "across all jobs and sectors need the right skills to use AI safely and effectively". The benchmark does not use the phrase "AI literacy". The six skills below are in its own three groups.
| Domain | Skill |
|---|---|
| Technical | Writing clear instructions for AI tools |
| Technical | Using AI tools to support routine processes and tasks |
| Non-technical | Using simple software that automates work tasks |
| Non-technical | Adjusting how an AI tool works to get better results |
| Responsible and ethical | Understanding the risks and consequences associated with AI use |
| Responsible and ethical | Analysing information using AI tools |
Skills England said anyone who completed an AI Skills Boost course covering all six "will receive a virtual badge to show they have met this benchmark". It is a benchmark, with no legal force.
What the competency framework expects of a worker
The AI Skills for Business Competency Framework, version 3, released in March 2026 and led by Dr Matthew Forshaw of The Alan Turing Institute, has a Worker persona for people who use AI tools in their roles "regardless of whether they are AI specialists". It expects them to be "well informed about the capabilities and limitations of the tools they use and apply professional judgement when interpreting AI-generated outputs".
How should you run AI literacy training?
Research co-developed with Skills England, published June 2026, named six design principles for effective AI skills training, which it called PRIMES. It said training should be:
- "practical, linked to real tasks and decisions"
- "reachable, easy to access in time, format and language"
- "integrated, built into work, systems, standards and governance"
- "modular, short, flexible and suitable for different starting points"
- "expandable, able to grow across roles, teams and organisations"
- "sustainable and kept up to date as AI tools and work practices change"
The report noted that its opinions "do not necessarily reflect the views of Skills England".
Our team training in data and AI fluency has people practise on their own tasks. How such training runs in practice for non-technical teams is covered in our adoption training guide, and budgets in what AI training for staff costs in the UK.
On method, the Commission warns that "in many cases, simply relying on the AI systems' instructions for use or asking the staff to read them might be ineffective". The rules staff are trained to follow usually live in a written AI use policy for staff.
On evidence, the Commission says: "There is no need for a certificate. Organisations can keep an internal record of trainings and/or other guiding initiatives." Where a certificate is wanted for other reasons, our guide to AI certifications for non-technical staff compares them.
On how far training has reached, the ONS article Artificial intelligence in UK businesses: 2023 to 2026 reports: "Only 11% of businesses (with 10 or more employees) reported that more than half of their workforce has received AI-related training." The figure comes from its business survey of 15 to 28 June 2026, published as official statistics in development. What holds adoption back is the subject of our AI transformation guide.
Frequently asked questions
Does Article 4 apply if our staff only use ChatGPT to draft text?
If your business is within the Act under Article 2(1), the Commission's answer is yes. Asked whether a company whose employees use ChatGPT "for, e.g., writing advertisement text or translating text" must comply, its guidance replies: "Yes, they should be informed about the specific risks, for example hallucination." Whether a UK business is within the Act at all is the Article 2(1) question above.
What happens to a business that ignores Article 4?
The Commission says national market surveillance authorities "could impose penalties and other enforcement measures", based on national laws. It says any sanction "must be proportionate", and "might, however, be more likely if there is proof of an incident due to lack of appropriate training and guidance of employees or other persons." It adds that "The AI Act doesn't create criminal offences or a right to compensation."
Do we have to test staff or appoint an AI officer?
No to both, on the Commission's guidance: "Article 4 of the AI Act does not entail an obligation to measure the knowledge of AI of employees", and "no specific governance structure is mandated to comply with article 4". Nor does the AI Office set rules by sector: "the AI Office does not impose requirements for specific sectors."
Should managers and developers get different training?
The Commission says "having different levels of training or learning approaches could be appropriate", and its own staff programme has packages for "generalists, managers, and developers (specialist)". Are developers already AI literate? "Normally yes, but it depends on the AI tool in question and their specific qualification." The competency framework expects leaders to be "literate in the general capabilities, limitations, and governance requirements" of the systems they adopt.
Is a UK AI literacy law on the way?
We found none in prospect. The King's Speech of 13 May 2026 contained no AI legislation. SI 2026/425 does require a code of practice on personal data in developing and using AI, but that duty falls on the data regulator, now the Information Commission (the ICO), and places no training duty on employers.
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