Do you know whether your use of AI touches the EU? And if it doesn't, does your AI literacy stack up?

AI literacy requirements under the EU AI Act have applied since February 2025, covering staff and others using AI systems on an organisation's behalf.

What about the recent changes?

You may have seen headlines about the EU's Digital Omnibus delaying parts of the AI Act. The timelines for high-risk AI systems, including certain AI used in recruitment, creditworthiness assessments and biometrics, have moved back to December 2027 and August 2028.

The AI literacy obligation was also updated, but not dropped. It originally asked organisations to “ensure a sufficient level” of AI literacy. As of late July 2026, the wording shifted to taking measures that “support the development” of AI literacy, with no specific level required for any individual. The wording is a lighter-touch than before, but the obligation remains. Organisations within the EU AI Act's scope are still required to take appropriate measures to help staff develop their understanding of AI, its risks, and how to use it responsibly.

What does this mean for UK businesses?

The EU AI Act can reach beyond EU borders, though the trigger is narrower than many assume. It isn't simply about handling EU data. Scope depends on factors such as placing an AI system on the EU market, putting one into service in the EU, or having the output produced by your AI system used in the EU. Some UK companies may fall within this, particularly where they supply AI systems into the EU or where their AI outputs are used there. Worth checking your own position rather than assuming either way.

What if your business has no EU exposure at all?

Even then, the underlying principle is simply good practice. Staff who understand what AI can and cannot do, where its risks lie, and how to use it responsibly, make better decisions and cause fewer problems, regardless of which regulator is watching. Shadow AI use, where staff quietly use tools like ChatGPT without any guidance, is a risk many businesses now face, EU exposure or not.

Building AI literacy into how your teams work isn't really about ticking a compliance box. It's a basic piece of operational hygiene for any business using AI in 2026, whether you trade with the EU or not.

If you'd like a hand working out where your business stands, or want to put a proportionate AI literacy programme in place either way, get in touch.

Disclaimer: I used Claude and ChatGPT to help research and refine this article.