The Long View: Responsible AI: The Brussels Effect, When the EU AI Act Becomes the World‘s Default

Research evidence excerpt

The Long View: Responsible AI: The Brussels Effect, When the EU AI Act Becomes the World‘s Default

Hugo Dubourg AC Europe Equity Research

(33-1) 4015 4471 10 July 2026 J P M O R G A N

hugo.dubourg@jpmchase.com

notify the market surveillance authority of the results using a template developed by

the AI Office. The FRIA is designed to complement any GDPR Data Protection

Impact Assessment.

• Does the EU AI Act mandate employee training? Article 4 requires providers and

deployers of AI systems to ensure a sufficient level of AI literacy among their staff

and other persons dealing with AI systems on their behalf. The dedicated Q&A does

not treat mandatory employee training as a universal regulatory requirement, but it

may be an appropriate outcome of a company’s own assessment. The EU provides a

living repository of AI literacy, including corporate examples such as Intesa

Sanpaolo’s AI Faculty — a programme covering the first 20,000 employees in its

first wave, with a goal to engage the whole workforce. The digital omnibus clarified

that providers and deployers must support the development of AI literacy of their

staff and other relevant stakeholders, though this does not require them to guarantee

any specific level of AI literacy of any individual. The Commission and member

states must support and facilitate providers and deployers in meeting these

obligations.

• Does the Act increase information about the environmental impacts of AI

systems? Providers of GPAI models must document the known or estimated energy

consumption of their model; where this is unknown, the estimation may be based on

the computational resources used. The Commission is empowered to adopt a

delegated act detailing measurement and calculation methodologies to allow for