Direct answer
Do we need to appoint an AI officer or AI compliance officer?
You describe: You wonder whether the AI Act, like the GDPR with the DPO, requires a mandatory officer and how to assign AI responsibility if not. Likely role: deployer (the organisation).
This applies now
- Article 4: AI literacyApplicable
Coming up
- Annex III: high-risk AIfrom 2 December 2027
The AI Act has no mandatory AI officer, no mandatory course format and no mandatory certificate. However, the Article 4 measures and high-risk governance do require that responsibility is assigned: someone who manages the register, guards the screenings and keeps the evidence. Many organisations assign this to an existing role such as the DPO, compliance or CISO; what counts is that it is demonstrably assigned.
Your first actions
- Take role- and context-specific AI literacy measures. Determine for each role, system and context which combination of instruction, guidance, practice or training is appropriate.
- Classify the use case and document the outcome. Assess Article 5, Article 6 and Annex III in that order and document purpose, context and any Article 6(3) exception.
Record this
- AI literacy measures record
- Article 6 and Annex III classification record
General interpretation, not legal advice. Checked against Regulation (EU) 2024/1689 and the Digital Omnibus (EU) 2026/1744; the official source remains authoritative.
Full map for your situationFollow-up questions
Execution
Make AI literacy demonstrable per role
You demonstrate the Article 4 duty to take measures with a file per role: who received which training, guidance and assessment. LearnWize records that per employee, audit-ready.
See LearnWize