On 2 February 2025, parts of the AI Regulation entered into force. The rules imply that employers must ensure that an adequate level of AI skills is upheld for all employees involved in the operation of the organisation or the use of an AI system.
According to Article 4 of the AI Regulation (Regulation (EU) 2024/1689 of the European Parliament and of the Council of 2024-06-13 on harmonised rules on artificial intelligence, also known as the Artificial Intelligence Act or the AI Act), all organisations developing and deploying AI solutions must ensure that their employees have sufficient AI skills. The requirement to ensure employees’ AI skills applies to all companies and authorities that provide, operate and use AI solutions.
The AI Regulation does not specify what actions users of AI solutions must take to ensure an adequate level of AI skills among employees, and it is up to each individual organisation to assess what constitutes such sufficient skills.
According to the Agency for Digitisation, AI skills can be divided into, for example, technological, practical and ethical understanding of AI technology. Technological understanding is about understanding how the AI system is built and developed, while practical understanding is about the ability to use an AI system. Ethical understanding is about understanding the implications that an AI system can have on both employees and society in general.
The assessment of whether employees have sufficient AI skills or not depends on the individual employee’s position in the company and the individual employee’s use of AI. The employees’ positions and existing knowledge are therefore crucial for the type of training the employees should be offered. Here, it will be necessary to assess the individual employee in terms of the extent to which it is necessary to raise their AI skills.
The Agency for Digitisation has published a guide on AI skills that can serve as an incentive for how employers can meet the requirements of employee AI skills. The guide also provides an example of a step-by-step approach that can be used to ensure sufficient skills in the organisation.
According to the guide, a step-by-step approach to ensuring adequate AI skills of employees could look like this:
- Identifying situations where AI is used that falls within the scope of the AI Regulation.
- Identifying employees and their roles in the organisation (both the employees who work with AI and the employees who are affected by AI).
- Consider what skills are needed for each employee.
- Plan organisational initiatives.
The guide also includes a number of suggestions for organisational actions, including: e-learning courses, AI professional communities, AI skills ambassadors and awareness campaigns.
You can read the entire Danish Agency for Digitisation’s guidance HERE
For further information about this or other questions, please contact our Danish member Mette Klingsten Advokatpartnerselskab and they will be thrilled to help you.
