Mind the gap: artificial intelligence literacy under the EU Artificial Intelligence Act and the gender divide

Article 4 of the EU Artificial Intelligence Act now requires organizations that build or deploy Artificial Intelligence in the EU to ensure a sufficient level of literacy across their workforce. The mandate intersects with persistent gender disparities, pushing companies to design targeted training and integrate literacy into broader compliance programs.

The EU Artificial Intelligence Act’s literacy obligations took effect on February 2, 2025, setting a new baseline for organizations that provide or deploy Artificial Intelligence systems in the EU, regardless of where they are based or the systems’ risk level. Article 4 requires a sufficient level of Artificial Intelligence literacy so teams can understand, use, and interact with systems responsibly. The Act defines literacy broadly as the skills, knowledge, and understanding needed to deploy responsibly, recognize opportunities and risks, and identify potential harms, underscoring that this is not only a technical requirement but an organizational capability.

Designing literacy programs must account for three factors specified in Article 4: the technical knowledge, experience, education, and training of staff and operators; the context in which a system will be used; and the persons or groups affected by that system. As a result, programs should reach beyond engineering to include business units such as sales and marketing, as well as contractors, vendors, clients, and impacted individuals. Training for a developer deploying a high-risk recruitment tool will differ from that for a marketing team using generative Artificial Intelligence for content creation, yet both are required. The Act does not prescribe methods, instead pointing to a living repository of good practices and allowing organizations to tailor their approach to roles, use cases, deployment contexts, risk levels, and business objectives.

While Article 4 does not explicitly require documentation for most systems, providers and deployers of high-risk Artificial Intelligence must demonstrate broader compliance, and literacy practices may form part of that evidence. Even where not mandated, maintaining records of programs, training, and competency assessments is strongly recommended to support transparency, accountability, and readiness to respond to regulators.

These requirements arrive amid uneven adoption of generative Artificial Intelligence by gender. Although senior women in technical roles are leading usage, studies cited in the article show women workers are 7 to 12 percent less likely to use generative Artificial Intelligence at work than men, and 20 percent less likely to use ChatGPT in the same occupation, with men reporting higher trust and understanding. Nearly half of women lack basic awareness of generative Artificial Intelligence. For organizations aiming to achieve a sufficient baseline under Article 4, a uniform curriculum is unlikely to work. Targeted, accessible pathways that address varying knowledge and confidence levels become both a compliance necessity and an inclusion imperative.

Artificial Intelligence literacy should not be treated as a standalone checkbox. The article recommends integrating it into existing compliance, risk, and training programs alongside obligations in content and safety, data protection and privacy, cybersecurity, and consumer protection, while aligning with diversity, equity, and inclusion goals. Practical steps include inventorying and categorizing all Artificial Intelligence systems, organizing cross-functional trainings, hosting company-wide sessions with senior leadership to set priorities, and documenting literacy efforts to prepare for audits, mergers, or acquisitions.

Bottom line: Artificial Intelligence is reshaping how organizations learn, decide, and deliver value. Embedded within a broader digital responsibility strategy, literacy becomes a competitive advantage and a foundation for responsible adoption. Building literacy among women is essential to ensure full participation and to foster inclusion, innovation, and accountability. Closing the Artificial Intelligence gap is not only a gender issue, it is a governance imperative.

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