EU AI Act · Article 4
AI literacy under the EU AI Act
What Article 4 asks of your organisation. Last updated:
Short answer
- If anyone in your organisation uses AI for work, including tools like ChatGPT or Copilot, Article 4 applies to you.
- You must take measures to build the AI literacy of staff and others who use AI on your behalf. This has applied since 2 February 2025.
- National authorities supervise and enforce it from 2 August 2026.
- No certificate or test is required. An internal record of training and guidance is enough to show what you did.
Key dates
| 2 February 2025 | Article 4 applies to providers and deployers of AI systems. |
|---|---|
| Mid-July 2026 | Digital Omnibus on AI amends Article 4. The obligation stays; no specific "sufficient" level is mandated anymore. |
| 2 August 2026 | National market surveillance authorities start supervising and enforcing Article 4. |
Who it applies to
Article 4 covers providers (organisations that develop AI systems) and deployers (organisations that use them). Most companies are deployers. The European Commission confirms that a company whose employees use ChatGPT to write advertising copy or translate text is in scope: those employees should know the specific risks, such as hallucination.
It is not limited to employees. "Other persons dealing with the operation and use of AI systems on your behalf" includes contractors, service providers and, depending on the risk, clients.
What changed in July 2026
The Digital Omnibus on AI amended Article 4. AI literacy remains an obligation for providers and deployers, but the law no longer mandates a specific or "sufficient" level, and it does not require you to guarantee any individual's level of AI literacy. The Commission and member states will publish practical examples of compliance, and the AI Board will adopt recommendations with common objectives.
For deployers of high-risk AI systems, the separate duty to train staff for human oversight (Article 26) is unchanged.
What a programme should cover
The Commission lists four steps every organisation should at least consider:
- General understanding. What is AI, how does it work, which AI do we use, and what are its opportunities and dangers?
- Your role. Do you develop AI systems, or use systems built by others?
- The risk. What do people need to know when working with these systems, which risks should they be aware of, and how are those risks mitigated?
- Tailored actions. Build on the above, matched to people's technical knowledge, experience, education and training, and to the context and purpose the AI is used for.
Legal and ethical aspects, including an understanding of the AI Act itself, belong in all four.
Is training mandatory?
Not in a fixed form. There is no one-size-fits-all format and no mandatory course. What is required are measures that fit your people and your use of AI. The Commission does warn that relying on a tool's instructions for use, or asking staff to read them, is in many cases ineffective. In practice, most organisations meet the duty with training and guidance targeted at each group.
Staff with a background in AI development can normally count as AI literate, but the Commission still expects you to check that they know the risks of the specific systems your organisation uses.
How to document it
No certificate is needed, and Article 4 does not require you to measure employees' knowledge. Keep an internal record of the training and other guidance you provided: who, when and on what. That record is what you show a supervisor.
Enforcement
Supervision is not with the EU AI Office but with national market surveillance authorities, from 2 August 2026. Penalties for infringements of Article 4 are set in national law, so they differ per member state.
A practical checklist
- List the AI tools and systems people use for work, including free ones.
- Decide who uses what, and what each group needs to know.
- Write a short AI use policy: approved tools, data that must not be entered, who to ask.
- Train and guide each group on their own work and the risks of their tools.
- Record what you did, and revisit it as tools change.
Using an AI assistant? It can run this check for you through our MCP server at https://mcp.spingras.io/mcp (tool: assess_article4_readiness).
Need help meeting Article 4?
Our half-day AI literacy workshop is built around this duty, on your team's own work.
Book a 30-min introSources
This page explains the law in general terms and is not legal advice.