An Expert Review of the AI Act
The EU AI Act and the Polish Act on Artificial Intelligence Systems establish that, from August 2026, AI literacy is a legal and strategic duty for all employers using AI systems, extending beyond HR or IT departments.
I recently had the pleasure of sharing my opinion and legal-business analysis in IT Reseller, a leading technology magazine. In the article, I examined the development of the EU AI Omnibus package, the requirements for labelling AI-generated content, and the new AI Chips 2.0 Directive.
Building on the topics I covered there, today, I would like to focus on one particularly important conclusion from that publication: how to turn the legal requirement for AI literacy into a sustainable competitive advantage for your organisation.
A Regulatory Shift: What Does the Law Require from Employers?
The introduction of the AI Omnibus package has changed the implementation timetable for high-risk systems, moving key deadlines to December 2027 and August 2028. However, this does not mean that organisations have greater flexibility regarding employee skills and competence.
Prohibited AI practices and the obligation to build AI literacy remain fully applicable.
Under the current guidelines, providers and organisations deploying AI systems must take active and documented educational measures. Your employees, as well as third parties operating AI systems on behalf of your company, must receive training appropriate to their roles and responsibilities.
The Boundaries of Business Responsibility
It is important to clearly separate the duties of the Board from the individual responsibilities of employees.
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What must you do as a leader? |
What does the law NOT require from you? |
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Create clear digital skills development plans. |
Guarantee a specific level of knowledge for every individual employee. |
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Adapt training to the employee’s technical knowledge and role within the organisation. |
Take responsibility for an employee’s unwillingness to learn. |
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Introduce internal evaluation and monitoring mechanisms. |
Turn every employee into a prompt engineer. |
Strategic Conclusion
The responsibility of the management team is to build, implement, and document an effective education system. Actual learning and applying knowledge is the employee’s responsibility.
What Does AI Literacy Really Mean? A Taxonomy of Key Terms
In management discussions, several basic concepts are often confused. To build effective development programmes and governance structures, we must clearly distinguish basic awareness from organisational maturity.
AI Awareness
An understanding that AI tools exist, including their basic applications and potential risks.
AI Literacy
A combination of knowledge, skills and attitudes that allows people to use AI consciously, critically and safely. This includes data protection, output verification and appropriate human oversight.
AI Fluency
The ability to adapt AI to complex and changing tasks and to adjust working methods smoothly.
AI Capability
The organisation’s overall ability to turn AI technology into measurable business results and return on investment.
Responsible AI and AI Governance
Formal structures covering accountability, ethics, risk management and legal control of AI systems.
These definitions show that developing AI competence within a company extends beyond writing prompts. The journey typically unfolds as follows:
AI knowledge → Tool usage → Critical application → Process integration → Responsible management
The Architecture of AI Literacy Levels within an Organisation
Not every employee needs to become a technical expert. When designing an education programme, we recommend a model based on a shared foundation, followed by specialised learning paths for different roles and business areas.
- Level 0: Not ready
- Level 1: Aware participant
- Level 2: Safe user
- Level 3: Functional practitioner
- Leadership and Process Owner Path
- Risk, Compliance, Audit and Legal Path
- Engineering and Data Science Path — Levels 4–5
Competence and Business Outcome Matrix
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Level |
Description |
Example Business Outcome |
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0. Not ready |
No knowledge, avoidance of AI tools or uncontrolled use of AI, including Shadow AI. |
The employee exposes the company to data leaks and copyright infringement. |
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1. Aware participant |
Understands basic concepts, opportunities and potential risks. |
Recognises which AI systems are being used within the organisation. |
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2. Safe user |
Uses approved tools, protects intellectual property and verifies AI-generated results. |
Completes everyday tasks efficiently without breaching security policies. |
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3. Functional practitioner |
Integrates AI into role-specific processes, evaluates quality and creates repeatable working methods. |
Builds a repeatable and efficient part of a process supported by AI. |
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4. Owner or leader |
Selects appropriate use cases and manages organisational change and risk. |
Takes responsibility for ROI and the safe implementation of AI within a team or business function. |
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5. Specialist |
Designs, builds, audits and directly supervises AI systems. |
Develops AI solutions and oversees high-risk systems. |
How can you translate these concepts into an actionable literacy programme for your company?
As a Booster of Innovation, we support Boards and senior executives in turning legal requirements into a structured and innovative business process. An effective AI education programme is based on four pillars:
1. Baseline Audit and Risk Mapping – Identify competence gaps and detect uncontrolled AI use, including Shadow AI.
2. Dedicated Training Paths – Develop a programme adapted to specific roles, from the Board and Compliance or HR teams to operational departments.
3. Evaluation and Certification Mechanisms – Create reliable documentation that meets the expectations of supervisory authorities.
4. AI Governance Framework – Establish clear policies that protect intellectual property, confidential information and customer data.
Prepare Your Organisation for the Changes Ahead
Implementing an AI literacy programme is not simply a legal requirement. It is a strategic investment in safe growth, digital maturity and the productivity of your team. Would you like to discuss how to implement a tailored AI literacy programme in your organisation and protect it against legal and operational risks?
Schedule a free 30-minute strategic consultation to explore your organisation’s needs:
Let’s discuss your organisation’s AI literacy requirements and design a programme specifically tailored to your industry.
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