From Dutch DPA urgency to demonstrable compliance — the complete plan for organisations to meet Article 4 EU AI Act in 2026, executed on the AI Academy platform.
Discover in 5 minutes where your organisation stands
The urgency is undeniable
The Dutch DPA is ringing the bell. Article 4 has been in force since February 2025. The Implementation Act is now in consultation. Organisations without a plan in 2026 carry material risk.
In the 6th RAN report the Dutch DPA marks the Dutch AI state red. AP chair Wolfsen: "Anyone who wants to prevent a new scandal must act now."
Since 2 February 2025 organisations are legally required to demonstrably ensure AI literacy for everyone working with AI — including the supply chain.
Article 4 is covered by sanctions up to €15m or 3% of global turnover. The AP and sectoral supervisors will test on evidence.
Public consultation on the AI Regulation Implementation Act runs until 1 June 2026. Afterwards the Dutch supervisory model becomes definitive.
Timeline
From the moment Article 4 became enforceable to the first full Dutch DPA inspection round — the coming 18 months are decisive.
What the Dutch DPA actually asks
The Dutch Data Protection Authority published a guidance document, a practical guide and a conference session specifically on AI literacy. This roadmap translates their four-step model into a 12-month work plan — iterative, not one-off.
Map which AI systems are in use, by whom, for which purpose — including shadow AI and procured tools with AI components.
Determine the level of AI literacy required per role: end-user, buyer, manager, compliance officer and executive each get different requirements.
Train, practice, document. Practice-based training with case studies demonstrably outperforms one-off theory sessions.
Measure the level, secure documentation and repeat the cycle. The AP expects an iterative process, not a one-time certificate.
Source: AP guidance "Getting started with AI literacy" (March 2025) and AP supervisory conference session "Building further on AI literacy" (session 6).
Role matrix
The AP is explicit: AI literacy is role-dependent. A compliance officer needs different skills than a marketing team member. This matrix is the starting point for the competence profiles in Q2.
The roadmap
Four quarters, four concrete work packages. Each quarter builds on the previous — from inventory to demonstrable certification.
Clearly map which AI your organisation uses and where the literacy gaps are.
Turn your inventory into an AI literacy plan with measurable goals per role group.
Roll out targeted training at scale — demonstrable, trackable and with certification per employee.
Close the cycle: re-measure the level, secure documentation, prepare for inspection or audit.
Platform deep-dive
A plan on paper is step one. The real work — demonstrably training, measuring and certifying hundreds of employees — requires the right tooling. Below are the characteristics the DPA expects, illustrated with the AI Academy platform.
Every employee starts at the basics and climbs to the level their role requires. The dashboard shows progress in real time.
Interactive case studies, quizzes and mini-assessments per module. Not passive video watching — active practice with real-life scenarios.
HR and compliance see in one screen: progress per employee, team heatmap, risk roles not yet ready, certificate status.
A time-stamped certificate per employee — linkable to your HR system, exportable as evidence during DPA inspection.
All content in Dutch and English. International teams can work in parallel, Dutch law is referenced correctly.
Data stays in Europe. No training data leaves to third parties. Role-based access, SSO available for enterprise.
Team of 50? Everyone invited in 30 minutes. Team of 500? Bulk import + automatic role assignment.
Every completed path ends in an official certificate. Time-stamped, linkable to HR systems, with a unique verification URL — so inspectors can independently verify.
Browse the modules, dashboard and certification flow
Assessment criteria
Not "the team had training" but "Jeroen completed module 6 on 12 March with score 82%". Inspectors expect this level of detail.
Training that follows the four steps from the DPA guide — identify, set goals, execute, evaluate — has the best chance during an inspection.
An HR professional needs to recognise different risks than a lawyer. The DPA expects training that fits the role, not one uniform "AI 101".
All relevant analyses in one place
The 14+ in-depth articles that guide you through the roadmap. Each phase is supported by one or more of these analyses.
Inventory your AI systems, test your team's knowledge level, and begin with phase one of this roadmap.