Who Owns the General AI Literacy Programme?

AI literacy programmes are appearing on the agenda across financial services firms, driven by regulatory expectations and the government's AI Skills Compact.

But before a single training session is designed, most firms hit the same obstacle: nobody is quite sure who is supposed to be leading the initiative.

HR and L&D assume Risk or Compliance will take the lead because of the regulatory angle. Compliance assumes HR will own it because it is "training". IT gets pulled in because AI is involved, and ends up holding a mandate it was never designed to carry.

The result is a programme that stalls before it starts, or one that launches without the authority, budget or cross-functional support it needs to succeed.

Getting ownership right is not a technical decision. It is an organisational design decision, and it matters as much as anything that happens inside the training itself.

Why the ownership question is surfacing now

AI literacy has moved from a nice-to-have to an operational necessity in a short period of time.

Regulators are increasingly asking firms to demonstrate that staff using or overseeing AI-assisted tools understand their capabilities and limitations. The government's AI Compact adds further pressure, signalling that workforce readiness is now a matter of public policy, not just internal best practice.

At the same time, AI-assisted tools are appearing across trading, underwriting, claims, customer service and compliance functions, often faster than firms can formally govern them.

This combination — rising regulatory scrutiny and rapid, uneven AI adoption — means literacy can no longer be left to whichever department happens to notice the gap first. Without a clearly accountable owner, the programme fragments: one business unit runs ad hoc sessions, another does nothing, and nobody can answer a regulator's question about organisation-wide readiness.

What firms have done before

Financial services firms are not solving this problem from scratch.

Many already run mandatory workforce-wide programmes such as anti-money laundering training, data protection training and financial crime awareness. These programmes offer a useful precedent for how ownership tends to work.

In most cases, a compliance or risk function is accountable for defining requirements and monitoring completion, while HR or L&D owns the delivery mechanics — scheduling, hosting content, tracking attendance. Business unit heads are expected to reinforce the message and ensure their teams participate.

A common pitfall when firms apply this pattern to AI literacy is letting ownership default to IT, simply because AI is a technology topic. IT can be an essential contributor — particularly around tooling, access and technical accuracy — but it rarely has the organisational mandate to require participation across trading desks, underwriting teams or customer-facing staff. Ownership needs to sit with a function that can set expectations for the whole workforce, not just for systems.

Where AI helps — and where it does not

AI itself has little to say about who should own the programme. This is fundamentally a question of organisational accountability, not a technical problem AI can solve.

Where AI-powered tools do add value is after ownership has been established. Once an accountable owner is in place, AI-assisted platforms can help monitor engagement across departments, tailor content to different roles — a trader needs a different depth of understanding than a claims handler — and track literacy levels over time so the owner can report progress with evidence rather than anecdote.

In other words, AI supports the person or function already accountable. It does not replace the need for someone to hold that accountability in the first place.

Practical steps for establishing ownership

Once a firm accepts that a dedicated owner is needed, a few practical steps tend to determine whether the programme succeeds.

• Secure executive sponsorship senior enough to mandate participation and release budget, rather than relying on goodwill from business units.
• Form a cross-functional steering group — typically HR/L&D, Risk & Compliance, and representatives from key business lines — so the programme reflects operational reality rather than a single function's priorities.
• Define clear escalation paths for when literacy gaps are identified, particularly where they intersect with existing risk or conduct frameworks.
• Review ownership periodically. A programme's needs at launch, when awareness-building dominates, differ from its needs once literacy is embedded and the focus shifts to maintenance and assurance.

Ownership is not a one-off decision. As the programme matures, the right owner — and the right supporting structure around them — may need to change.

Example

A London-based commodities trading firm is preparing for increased use of AI-assisted trade surveillance tools. Compliance raises concerns that traders and operations staff lack a consistent understanding of how the tools work and their limitations. HR/L&D and Compliance both assume the other is leading the response.

The Chief Operating Officer steps in and designates the Head of Compliance as the accountable sponsor, given the regulatory driver behind the initiative, while L&D retains responsibility for delivery design and rollout. A quarterly steering group including trading desk heads is formed to ensure content remains operationally relevant.

The ownership ambiguity is resolved within one quarter, and the programme launches with a clear accountable sponsor and cross-functional input from the outset.

FAQs

• Should IT own the AI literacy programme since it involves technology?

  IT typically plays an important supporting role, particularly around tooling and technical accuracy, but should not own the programme alone. AI literacy is a workforce capability and risk management issue that spans trading, operations, compliance and customer-facing teams, and ownership needs the organisational mandate to reach all of them.

• Can ownership sit with a single department in a smaller firm?

  Smaller firms may combine ownership and delivery in one role, such as Head of Operations, given limited resources. Even at reduced scale, however, cross-functional input from risk, compliance and business leads remains important so the programme does not become too narrow.

• How does the AI Compact affect who should own this programme?

  Increasing regulatory expectations around workforce readiness mean ownership should sit with a function accountable for compliance and workforce risk. This is why Risk, Compliance or COO sponsorship is becoming more common than defaulting to HR or IT alone.