A team leader at a secondary school is asked in the Dutch department meeting whether the grading tool two colleagues have used since the summer is allowed under the AI Act. That same week, the staff training day includes an hour on AI literacy, because that is supposed to be mandatory. The two questions belong together, and the answer to the second (is it really mandatory?) is shorter than you might think.
Article 4 of the AI Act has applied to schools since 2 February 2025. A school that uses AI systems under its own responsibility is a deployer, and has to take measures aimed at a sufficient level of AI literacy among the staff who work with those systems. The text mentions no course, no certificate and no number of hours. What counts as sufficient depends on knowledge, experience and the context of use, and the Act explicitly mentions the people on whom the AI is used. In a school, those are pupils.
Why does Article 4 apply to a school?
The Act is addressed to providers and deployers. A school does not build AI. It uses it: a teacher asking a chatbot to draft a test, a form tutor asking it to rewrite a letter to parents, a learning tool with an adaptive feature. Anyone who uses an AI system under their own authority is a deployer; the legal entity behind the school is the board. The text is in Regulation (EU) 2024/1689; what Article 4 says, and why it contains no course requirement, is set out in our overview of AI literacy in 2026.
The Digital Omnibus of July 2026 turned it into a best-efforts obligation: take measures that support the development of AI literacy. That changes little about what you do, but it does change the tone of what you record: not "our teachers are AI literate", but "this is what we did for each role, and this is why it fits".
Two phrases in Article 4 carry more weight in education than elsewhere. "On their behalf" covers supply teachers, trainee teachers and the external tutor running exam preparation. And "the persons on whom the AI systems are to be used" are minors here, whose name, date of birth, family situation, support history and results sit in one place. In its questions and answers on Article 4, the European Commission says that context determines what is sufficient. For a school, that is the reason to look at each role separately.
Why is the bar higher in education?
Because education is one of the eight areas in Annex III. The Act lists AI that determines admission to a programme, evaluates learning outcomes, determines the appropriate level of education or detects prohibited behaviour during tests. An AI system intended for one of those purposes is high-risk. From 2 December 2027, the duties in Article 26 apply to it, including human oversight by people with the knowledge and authority to intervene. What matters is the intended purpose the provider has documented, and how this applies in practice varies by system and by school.
A chatbot that rewrites a worksheet or comes up with a practice test does not fall under this. Generating, summarising and translating text is not in Annex III. That changes once a tool is built to grade essays, place pupils at a level or watch for irregular behaviour during a digital test. Where the line falls is covered in our article on when an AI application counts as high-risk.
One category is not high-risk but prohibited: AI that infers pupils' emotions in an educational setting, except for medical or safety reasons. A tool that scores "engagement" during an online lesson has to be switched off. The other obligations are covered in our guide to the EU AI Act for employers.
What counts as sufficient for each role?
The question is not how many hours, but what someone in this role needs to understand to use AI responsibly. That varies, and the differences are what you record.
| Role | What the person needs to understand | What the school records |
|---|---|---|
| Teacher using AI for lesson materials and admin | Which tools are allowed, which pupil data stays out, that answers need checking | The explanation this group received, and the decision on each tool |
| Teacher or form tutor using AI in feedback and assessment | That a grade remains the teacher's call, which tools were assessed for this and when a tool assesses rather than assists | What was agreed for each tool, and who was briefed |
| Special needs coordinator, tutor with pupil support files | That support notes and a development plan contain special category data, which belongs only in an assessed environment | Which environment that is, and the briefing this group received |
| Exam officer, assessment committee | When a tool falls under Annex III, and what human oversight then involves | The assessment of each system, dated |
| ICT and procurement | Vendor, data processing agreement under the Privacyconvenant (the education sector's privacy agreement), training policy, country, risk | The questionnaire and the register of assessed tools |
| Board and school leadership | The statuses per tool, who assesses a new tool and their own responsibility as deployer | The policy, the decisions and who took them |
The largest group is in the first row, where the briefing is simplest. Why not everyone needs the same briefing is explained in our article on whether every employee needs AI training.
What does this look like in a school?
A board with eight schools holds a staff training day at each one. The message is the same everywhere: Copilot on the school account is allowed, pupil data does not go into free tools, and if in doubt, ask the ICT coordinator. The attendance lists go into the file.
Six months later, an inventory shows that besides Copilot, the free version of ChatGPT, MagicSchool, Curipod and a grading tool for writing assignments are in use. No decision was ever taken on the last two. The Dutch department has the grading tool suggest a first mark for essays, and usually adjusts it.
That is not an incident. It shows two things. The training day was a single moment, and the work carried on, with tools that did not yet exist. And the grading tool raises a different question from the chatbot: does the tool assess, or does it help the teacher assess? The board asks the vendor what intended purpose it has documented, decides on the tool and briefs the department: the mark stays with the teacher.
How do you show it?
With your own records, since no certificate is required. Three kinds of evidence each tell you something different: the briefing for each role and who received it, the decision on each tool and what then happened in daily work. The last is missing at most schools, and it is what a regulator will ask about in the end. How the three fit together is set out in our article on demonstrating AI literacy.
The third part requires the school's decision to be there when a teacher opens a tool, and a way to see afterwards what happened without knowing who it was. BeeSensible matches a catalogue of AI tools against the use observed in the organisation, shows the decision on a tool in the browser when someone opens it, and counts what the person did next. The figures are aggregated and carry no user ID. What that means for a school board is explained on the page about education.
