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Article 4: AI literacy.

Reviewed

Short answer

Article 4 of the AI Act requires providers and deployers of AI systems to take measures to support the AI literacy of their staff and of others who operate or use AI systems on their behalf; since the Digital Omnibus took effect on 27 July 2026, it no longer requires them to guarantee any specific level. The duty has applied since 2 February 2025, national market surveillance authorities supervise it from 2 August 2026, and the Commission says no certificate is needed.

Official sources: AI Act, Article 4 (consolidated) · European Commission: AI Literacy Q&A

The wording, before and after

Article 4(1) of the AI Act before and after Regulation (EU) 2026/1744
Text
Until 26 July 2026“Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf …”
From 27 July 2026“Providers and deployers of AI systems shall take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf … This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual.”

Both versions ask you to take into account people’s technical knowledge, experience, education and training, the context in which the AI systems are used, and the people they are used on. The new Article 4(2) and (3) add that the Commission and member states support providers and deployers, in particular SMEs, the Commission publishes practical examples on the AI Act’s single information platform, and the AI Board adopts recommendations.

What the Commission says

Points from the Commission's AI Literacy questions and answers
QuestionCommission’s answer
Do we have to measure employees’ AI knowledge?No; Article 4 does not entail an obligation to measure it.
Do we need a certificate?No; an internal record of trainings or other guiding initiatives is enough.
Who enforces it, and from when?National market surveillance authorities, not the AI Office, from 2 August 2026.
What happens if we do not comply?National authorities can impose penalties and other measures under national law; sanctions must be proportionate, and are more likely where an incident results from a lack of training and guidance.
Can employees sue over missing training?The AI Act does not create criminal offences or a right to compensation; liability depends on national law.
Does it apply to companies outside the EU?Yes, as for the rest of the Act, when the AI system is placed on the EU market, used in the EU or affects people in the EU.

Article 99 sets no specific fine ceiling for Article 4: it is not in the lists of paragraphs 3 to 5. Member states lay down penalties for infringements in general (Article 99(1)).

A practical routine (our suggestion, not a legal list)

  • List the AI tools in use and who uses them for what.
  • Give each group what it needs: what the tool can and cannot do, its typical errors, data you must not paste in, and when a human must check.
  • Content teams: the labelling rules for deepfakes and public-interest text (Article 50(4)).
  • Keep a dated record of trainings, guides and briefings.
  • Update the material when a tool or its use changes.

Questions

Is AI literacy training mandatory under the AI Act?
Taking measures is mandatory; a particular training format is not. Since 27 July 2026, Article 4 asks providers and deployers to take measures to support AI literacy and says they need not guarantee any specific level; the Commission accepts an internal record and does not require certificates.
Does a company that only uses ChatGPT-style tools have to do this?
Yes: Article 4 applies to deployers of AI systems, which includes a company using AI tools under its authority for work. Only purely personal, non-professional use is outside the Act.

Sources

Last reviewed by Volkan Çatak, Founder, Proofcan.

Not legal advice. This page explains official texts in plain words and links each one; check the sources, or a lawyer, before relying on it for a decision.