Dutch organisations should treat AI literacy as the baseline and certified competence as the gate. Article 4 of the EU AI Act expects deployers to make sure staff who work with AI systems are sufficiently literate. Anyone who approves agent actions, especially in insurance underwriting and claims, needs tested competence that De Nederlandsche Bank or the AFM could inspect.
What is the baseline every Dutch employee needs?
Literacy for agents is narrower and more practical than general AI awareness. Everyone who works beside an agent should be able to answer four questions about any action it takes:
- How far may it act here? Depth runs from 1 (read) through 2 (draft, a person sends), 3 (routine work within bounds) and 4 (money or hard-to-undo actions) to 5 (coordinating other agents).
- What was the verdict? Allowed, held for a named person, refused as outside its bounds, or withheld at the platform floor.
- Where did the facts come from? Sealed by the system of record, signed by a named party, declared by a person, or external.
- Is its authority current? Agent certificates lapse after 90 days, and a run that clears no depth drops the agent to depth 1 the same day.
Why do insurers and underwriters need more?
Annex III of the EU AI Act lists risk assessment and pricing for life and health insurance as high-risk. Where an agent contributes to that work, Article 14's human oversight requirement applies, and oversight is only as good as the people doing it. An underwriter who cannot tell a sealed medical record from a declared answer on a form cannot oversee an agent's pricing draft.
Underwriters therefore need to understand how the agent reached its draft, what evidence it relied on, and which bound held the action. The underwriter brief for insurance in the Netherlands goes into the role in depth, and the compliance officer brief for insurance in the Netherlands covers the second line.
Which Dutch and EU rules shape the training?
De Nederlandsche Bank supervises banks, insurers and pension funds on prudential matters, and the AFM supervises conduct in financial markets. GDPR applies to personal data, and Article 22 limits decisions based solely on automated processing that have legal or similarly significant effects. DORA applies to financial entities and expects ICT risk, including third-party technology, to be managed by people who understand it. The EU AI Act adds Article 4 literacy, and for high-risk systems Article 14 oversight and Article 26 deployer obligations.
This is an explanation of the rules, not legal advice; confirm how they apply to you with counsel.
What does the agent do and what does the underwriter keep?
| Work | Agent | Underwriter |
|---|---|---|
| Collecting and summarising the application | Reads and summarises at depth 1 | Checks the summary against source |
| Drafting a risk assessment | Drafts at depth 2 | Decides whether it stands |
| Proposing a price within the insurer's own limits | Drafts and holds | Approves, adjusts or declines |
| Declining cover | Never decides alone | Owns the decision and the reason |
Are micro-credentials enough?
A micro-credential is a short, focused credential for one skill. It suits literacy well: a short test on depth, verdicts and provenance, recorded per person. It is not enough on its own for approvers. Someone who releases held actions should be tested on real decisions over a sustained period, with any missed red line counting as a fail, and should hold a credential that expires and must be renewed.
Whatever you use, make it checkable. A credential that a supervisor can verify at source, with lapsed or revoked status on the same page, is stronger evidence than a PDF in a shared folder. See AI literacy and certification for people who work with agents for the full model, and the France guide for a neighbouring market.
Where the Academy fits
Pryme Intelligence Academy separates the two needs. The free Foundations badge covers literacy in about four hours and has no expiry. The Operator certificate, for people who review agent decisions, requires a written exam and a two-week practicum signed off by a Pryme assessor, and is valid for 12 months.
Questions people ask
Does Article 4 require a certificate?
No. It requires a sufficient level of AI literacy, judged by role and context. A certificate is one way to show it; a record per person, tied to what they oversee, is the minimum.
Does English-language training meet the expectation?
If staff work in English and understand it well, yes. Where reviewers handle customer documents in Dutch, test them on Dutch cases so the assessment matches the job.
Who should own AI literacy in a Dutch insurer?
Typically the risk or compliance function, with learning and development delivering it. The owner should be able to show the record to De Nederlandsche Bank or the AFM on request.