31 October 2025

Building further on AI literacy: the Dutch Data Protection Authority releases updated guidance

Society

The Dutch Data Protection Authority (AP) has released the second edition of its guide Building further on AI literacy. Expanding on the earlier publication Getting started with AI literacy, this updated document provides a deeper look into the legal obligations for organizations developing or using AI. It offers practical steps for integrating AI literacy in a sustainable and strategic way.

According to the AP, AI literacy is not optional but a legal requirement for organizations that develop or deploy AI systems. Employees and contractors must have sufficient knowledge and skills to use AI responsibly. This not only ensures compliance with the EU AI Act but also safeguards fundamental rights and values.

The AP stresses that AI literacy must be an ongoing and context-specific process. There is no ‘one size fits all’ approach; the implementation depends on the organization’s sector, size, and roles. To embed AI literacy effectively, organizations must combine training and awareness efforts with management involvement and continuous evaluation.

The guide outlines a four-step plan for organizations to build sustainable AI literacy:

  1. Identify – Map out which AI systems are used, who works with them, and what risks and opportunities they present.
  2. Define goals – Set measurable objectives based on risk levels and employee roles.
  3. Implement – Provide training, awareness programs, and ensure management involvement.
  4. Evaluate – Monitor progress and adapt strategies as needed.

The AP urges organizations to approach AI literacy from both directions: bottom-up and top-down. Leadership must allocate resources, set priorities, and foster a culture of responsibility. In 2026, the AP will assess the national state of AI literacy and organize a follow-up seminar to facilitate knowledge sharing.

 

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