Are employers required to train employees on AI?
It depends on where you operate, and the two answers are opposite. In the European Union, yes in the sense that matters: Article 4 of the EU AI Act requires providers and deployers to take measures that support AI literacy for staff and anyone operating AI on their behalf. No specific level, course or certificate is mandated. In the United States, no. There is no federal requirement, and no state requires employers to train employees on AI. Six states regulate AI in employment, and not one of them mandates training.
Verified against primary sources and our own 50-State AI Law Atlas. Every row below carries its citation and the date it was checked.
European Union
Measures required, not a courseProviders and deployers of AI systems, for staff and anyone operating AI on their behalf
Yes, in the sense that matters: you must take measures that support AI literacy, and be able to show them. No specific level is mandated.
Article 4 of the EU AI Act applies to providers and deployers of AI systems and reaches staff and other persons operating or using AI on their behalf. The Digital Omnibus, Regulation (EU) 2026/1744, in force 27 July 2026, replaced the original duty to ensure a sufficient level with a duty to take measures supporting the development of AI literacy, and the Commission states that no specific or sufficient level is now mandated. Measures must take into account technical knowledge, experience, education and training, the context of use, and the people the systems are used on. Article 4 has applied since 2 February 2025, with national market surveillance supervision from 2 August 2026. There is no required format, no required certificate, and no obligation to test employees. What you must be able to produce is evidence that you took reasonable measures.
Regulation (EU) 2024/1689 Article 4, as amended by Regulation (EU) 2026/1744. In force: 2 February 2025, amended 27 July 2026. Checked 2026-08-22. Source
European Commission guidance
Measures required, not a courseHow the Commission reads Article 4 after the amendment
The Commission says AI literacy remains an obligation, but no specific level is mandated and no certificate is required.
The Commission's AI literacy questions and answers confirm the position after the Digital Omnibus: the obligation persists, no specific or sufficient level of literacy is required, there is no obligation to measure employee AI knowledge, no training format is prescribed, and no certificate is required. An internal record of the measures taken can suffice. This is the single most misquoted point in the market, and it cuts against the way most training is sold, including ours.
European Commission, AI literacy questions and answers. In force: Current guidance. Checked 2026-08-22. Source
United States, federal
No training requirementPrivate employers generally
No. There is no federal law requiring employers to train employees on AI.
The US Department of Labor's AI Literacy Framework, Training and Employment Notice 07-25, is expressly voluntary guidance for the public workforce system and its partners. It is a reference for what good AI literacy contains, not a mandate, and following it creates no legal presumption. Existing federal employment law still applies to how AI is used, notably anti-discrimination law, but that governs outcomes rather than requiring training.
US DOL, Training and Employment Notice 07-25. In force: Voluntary guidance. Checked 2026-08-22. Source
United States, all 50 states
No training requirementEvery state AI law currently on the books
No state requires employers to train employees on AI. Six states regulate AI in employment, and none of them mandate training.
Across the 78 state AI laws tracked in our 50-State AI Law Atlas, six touch employment, and not one imposes an employee training requirement. Illinois requires notice, explanation and consent before using AI to analyse video interviews, and separately prohibits AI that has a discriminatory effect in employment. Maryland requires consent before facial recognition in interviews. New York City requires an annual independent bias audit of automated employment decision tools. Connecticut's omnibus act creates staged duties from October 2026. Illinois restricts AI in public-school teacher evaluations from 2027. Every one of these governs notice, consent, auditing or discrimination. None says train your staff.
Illinois 820 ILCS 42 and HB 3773; Maryland HB 1202; NYC Local Law 144; Connecticut SB 5. In force: Various, 2020 to 2027. Checked 2026-08-02. Source
- Training required
- The law names training, or a level of competence, as an obligation.
- Measures required, not a course
- You must take steps that support AI literacy and be able to show them. No specific course, exam, certificate or level is mandated.
- Only in certain conditions
- The duty attaches to a particular sector, role or use, not to employers generally.
- No training requirement
- Nothing here requires you to train employees on AI. Other duties may apply, such as notice, consent or an audit.
Are employers required to train employees on AI?
It depends entirely on where you operate. In the European Union, yes in effect: Article 4 of the EU AI Act requires providers and deployers to take measures that support AI literacy among staff and anyone operating AI on their behalf. In the United States there is no such requirement, federally or in any state. Six states regulate AI in employment, and none of them mandate training.
Does the EU AI Act require a specific AI training course or certificate?
No. Since the Digital Omnibus amended Article 4 on 27 July 2026, the duty is to take measures supporting the development of AI literacy. The European Commission states that no specific or sufficient level is mandated, there is no obligation to measure employee AI knowledge, no training format is prescribed, and no certificate is required. An internal record of the measures taken can suffice.
Is the US Department of Labor AI Literacy Framework mandatory?
No. Training and Employment Notice 07-25 is voluntary guidance for the public workforce system and its partners. It describes what AI literacy should contain and is a useful reference, but it imposes no obligation and following it creates no legal presumption of compliance.
Which US states regulate AI in hiring?
Illinois, Maryland, New York City and Connecticut have the clearest employment rules today. Illinois requires notice, explanation and consent before AI analyses a video interview, and prohibits AI that has a discriminatory effect in employment. Maryland requires consent for facial recognition in interviews. New York City requires an annual independent bias audit of automated employment decision tools. Connecticut's duties are staged from October 2026. None of these require employee training.
What evidence would a regulator actually ask for?
Under Article 4 the obligation is one of effort, so what you can show is the record: which roles received what, calibrated to their technical knowledge and the context the AI is used in, when it happened, and how it is refreshed as systems change. Completion alone is weak evidence. Records that show what a person demonstrated are stronger.
If nothing requires training, why would an employer do it?
Because the duties that do exist land on the people using the systems. Anti-discrimination law, notice and consent rules, bias audits and sector supervision all assume someone in the organisation understands what the AI is doing. Training is how that understanding gets there, and the record of it is what a regulator, a procurement questionnaire or opposing counsel will ask to see.
If you operate in the EU, what you can show matters more than what you bought
Article 4 is an obligation of effort, so the record is the compliance position. Useful evidence names which roles received what, calibrated to their technical knowledge and to the context the AI is used in, when it happened, and how it is refreshed as the systems change. A completion tick is weak evidence. A record of what a person demonstrated is stronger, which is the whole reason our own programs end each topic with a graded explanation rather than a checkbox.
Related free instruments: Article 4 in full, the 50-State AI Law Atlas, and the scope wizard.
This page is a study aid, not legal advice. Obligations depend on your systems, your role and your sector, and the law is moving. Every source is linked above so you can check it yourself, which is the only way any of this should be used.