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Two references, one program

DOL AI Literacy Framework vs EU AI Act Article 4

One is voluntary and tells you what to teach. The other is binding and tells you that you must, without telling you what. Read together they are a specification and a duty, and most organizations exposed to both run a single program against both.

The DOL AI Literacy Framework (TEN 07-25) is voluntary U.S. guidance defining what AI literacy training should contain. EU AI Act Article 4 is a binding obligation on providers and deployers of AI systems, applicable since February 2, 2025 and enforceable by national authorities since August 2, 2026. Organizations exposed to both usually run one literacy program built to the DOL framework and evidenced for Article 4.

Last verified against the DOL source: August 20, 2026. What changed

Eight lines that decide it

Side by side

Instrument
USTraining and Employment Notice No. 07-25, with the AI Literacy Framework as its attachment
EURegulation (EU) 2024/1689, Article 4, as rewritten by the Digital Omnibus (Regulation (EU) 2026/1744)
Issued by
USU.S. Department of Labor, Employment and Training Administration
EUEuropean Parliament and Council, enforced by national market surveillance authorities
Key dates
USIssued February 13, 2026
EUApplicable since February 2, 2025. Rewritten with effect from July 27, 2026. Enforcement powers since August 2, 2026
Legal force
USVoluntary guidance. No mandate, no certification, no enforcement mechanism
EUBinding obligation on providers and deployers of AI systems
Who it addresses
USThe public workforce and education systems: workers and students, employers, training providers, state and local agencies
EUProviders and deployers, reaching staff and other persons operating or using AI systems on their behalf
What it specifies
USFive foundational content areas and seven delivery principles, each with five concrete markers: 60 checkpoints in all
EUMeasures supporting the development of AI literacy, calibrated to technical knowledge, experience, education, context, and the persons the AI is used on. No syllabus, no fixed level
What it asks you to show
USNothing. Alignment is a design choice you can evidence voluntarily, and increasingly a procurement criterion
EUA record of the measures taken: who is covered, what was delivered, how capability was evidenced, and the review cadence
Funding hook
USTEGL 03-25 encourages WIOA Title I funds and governor's reserve monies for AI skills development
EUNone. The driver is legal exposure, not funding
Three readings

Which one applies to you

US only

The DOL framework is your reference. Nothing binds you, but it is the federal vocabulary your funders, boards and procurement committees are starting to write requirements in.

Read the framework guide
EU exposed

Article 4 is the obligation and it is already enforceable. The DOL framework is the design specification that helps you answer it, and the evidence file is what an authority actually asks to see.

How to document Article 4
Both

Run one literacy program built to the 60 DOL checkpoints, and keep the Article 4 record beside it: roles covered, measures taken, capability evidenced, review dated.

The EU dates that bind

One caution on urgency: the Digital Omnibus deferred most stand-alone high-risk obligations to December 2027 and August 2028. Article 4 was not deferred. Anyone selling you a deadline should be able to name which provision it comes from. Check your scope against the current text.

Questions

Is EU AI Act Article 4 like the DOL AI Literacy Framework?

They answer different questions. Article 4 is a binding obligation that says you must take measures to support AI literacy among the people operating AI on your behalf, without prescribing content. The DOL framework is voluntary guidance that prescribes content in detail: five content areas, seven delivery principles, 60 markers. That is why they compose so well. The EU tells you that you must, and the DOL framework is a credible answer to what.

Does building a program to the DOL framework satisfy Article 4?

It covers the content dimension well, and it is defensible design evidence. It does not by itself discharge the obligation. Article 4 is contextual to your roles, your AI systems and the people they are used on, and following any collected set of AI literacy practices creates no presumption of compliance. You still map the training to your own roles and systems, evidence completion, and review it as things change.

Which came first, Article 4 or TEN 07-25?

Article 4 entered into application on February 2, 2025. TEN 07-25 was issued a year later, on February 13, 2026. The Digital Omnibus then rewrote Article 4 with effect from July 27, 2026, so an organization that mapped its program to the original wording is working from superseded text.

We are US only. Does Article 4 matter to us?

Only if you place AI systems on the EU market or use AI whose output is used in the EU. If neither is true, the DOL framework is your reference and the comparison is useful mainly because EU-facing customers and partners increasingly ask about it in procurement.

One program, both references

AI Literacy and Professional Conduct is built to the DOL framework and produces the assessed, dated, per-seat record an Article 4 file needs. Pair it with AI Governance for the person accountable, and the bundle is $479 instead of $149 plus $399 separately.

Score your program firstSee the literacy program, $149

GAGE (Global Academy of Generative-AI Education) is a private education company, not affiliated with or endorsed by the U.S. Department of Labor. DOL does not certify or endorse training programs. Framework summaries are drawn from the public TEN 07-25 document. Read TEN 07-25 on dol.gov. Last verified: August 20, 2026.

GAGE is not affiliated with, or endorsed by, the European Union. General information, not legal advice.

Last verified against the DOL source: August 20, 2026. What changed