Praxikon

Guidelines

Building further on AI literacy

PublishedDutch Data Protection Authority (AP)23 Oct 2025

Second guidance note by the Dutch Data Protection Authority on AI literacy, supplementary to 'Getting started with AI literacy'. Goes deeper into the legal obligation and, with practical examples, sets out a multi-year action plan by which organisations can approach AI literacy strategically and sustainably. The Authority states that the law does not prescribe what specific measures are necessary and that the required level of knowledge depends on context and risk. Note: this document predates the Digital Omnibus on AI and describes Article 4 still in its previous formulation; since 27 July 2026 it is an obligation to take measures without a guaranteed individual level.

What this means for you

Article 4 has applied since 2 February 2025 and this is the guidance that the Dutch supervisor will use as a benchmark for an approach.