From Dutch DPA urgency to demonstrable compliance — the complete plan for organisations to meet Article 4 EU AI Act in 2026, executed with LearnWize.
Discover in 5 minutes where your organisation stands
The urgency is undeniable
The Dutch DPA is ringing the bell. Article 4 has applied since February 2025 and the amended wording has applied since 27 July 2026. Consultation on the Implementation Act has closed. Organisations without an appropriate plan carry material risk.
In the 6th RAN report the Dutch DPA marks the Dutch AI state red. AP chair Wolfsen: "Anyone who wants to prevent a new scandal must act now."
Article 4 has applied since 2 February 2025. Since 27 July 2026, providers and deployers must take measures to support the development of AI literacy. They do not have to guarantee a specific individual level.
AI literacy is not a standalone fine question but an expectation from supervisors and sectors, and part of human oversight for high-risk AI (Article 14). The AP and sectoral supervisors look at demonstrable policy.
The consultation on the AI Regulation Implementation Act closed on 1 June 2026. Further national proceedings will determine the Dutch supervisory structure.
Timeline
From the start of Article 4 to the amended wording and national enforcement: these moments determine the approach.
What the Dutch DPA actually asks
The Dutch Data Protection Authority published a guidance document, a practical guide and a conference session specifically on AI literacy. This roadmap translates their four-step model into a 12-month work plan — iterative, not one-off.
Map which AI systems are in use, by whom, for which purpose — including shadow AI and procured tools with AI components.
Define suitable learning goals and measures per role: end users, buyers, managers, compliance officers and executives have different contexts.
Train, practice, document. Practice-based training with case studies demonstrably outperforms one-off theory sessions.
Evaluate whether the measures work, secure documentation and repeat the cycle. Dutch DPA guidance recommends an iterative process, not only a one-time certificate.
Source: AP guidance "Getting started with AI literacy" (March 2025) and AP supervisory conference session "Building further on AI literacy" (session 6).
Role matrix
Dutch DPA guidance is role and context based. A compliance officer has different learning goals from a marketing team member. This matrix is the starting point for the competence profiles in Q2.
The roadmap
Four quarters, four concrete work packages. Each quarter builds on the previous — from inventory to demonstrable certification.
Clearly map which AI your organisation uses and where the literacy gaps are.
Turn your inventory into an AI literacy plan with measurable goals per role group.
Roll out targeted training at scale — demonstrable, trackable and with certification per employee.
Close the cycle: re-measure the level, secure documentation, prepare for inspection or audit.
Platform deep-dive
A plan on paper is step one. The real work — demonstrably training, measuring and certifying hundreds of employees — requires the right tooling. Below are the characteristics the DPA expects, illustrated with LearnWize.
Every employee starts at the basics and climbs to the level their role requires. The dashboard shows progress in real time.
Interactive case studies, quizzes and mini-assessments per module. Not passive video watching — active practice with real-life scenarios.
HR and compliance see in one screen: progress per employee, team heatmap, risk roles not yet ready, certificate status.
A time-stamped certificate per employee — linkable to your HR system, exportable as evidence during DPA inspection.
All content in Dutch and English. International teams can work in parallel, Dutch law is referenced correctly.
Data stays in Europe. No training data leaves to third parties. Role-based access, SSO available for enterprise.
Team of 50? Everyone invited in 30 minutes. Team of 500? Bulk import + automatic role assignment.
Every completed path ends in an official certificate. Time-stamped, linkable to HR systems, with a unique verification URL — so inspectors can independently verify.
Browse the modules, dashboard and certification flow
Assessment criteria
Not "the team had training" but "Jeroen completed module 6 on 12 March with score 82%". Inspectors expect this level of detail.
Training that follows the four steps from the DPA guide — identify, set goals, execute, evaluate — has the best chance during an inspection.
An HR professional needs to recognise different risks than a lawyer. The DPA expects training that fits the role, not one uniform "AI 101".
All relevant analyses in one place
The 14+ in-depth articles that guide you through the roadmap. Each phase is supported by one or more of these analyses.
Inventory your AI systems, test your team's knowledge level, and begin with phase one of this roadmap.