Article 4 of the EU AI Act is one of the shortest and least discussed provisions in the regulation, but it is one of the first to take effect and one of the broadest in scope. It states that 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, taking into account their technical knowledge, experience, education and training, the context in which the AI systems are to be used, and the persons or groups of persons on which the AI systems are to be used.
This obligation became enforceable on 2 February 2025. It applies to all providers and deployers — not just those operating high-risk AI systems. If your business uses any AI system in its operations, Article 4 applies to you.
The AI literacy obligation has received relatively little attention compared to the prohibited practices or high-risk system requirements. There are several reasons for this. The provision is brief and appears straightforward, leading many to underestimate its practical implications. The concept of AI literacy is not defined with precision in the regulation, creating uncertainty about what compliance looks like. And because the obligation applies broadly — to every business that uses AI, regardless of risk level — it does not trigger the same urgency as the high-risk provisions that apply to a smaller group of businesses.
The result is that many businesses have focused their AI Act compliance planning on the August 2026 deadline for high-risk systems and have not yet addressed the AI literacy requirement that has been enforceable since February 2025.
The AI Act defines AI literacy in its recitals as the skills, knowledge, and understanding that allow providers, deployers, and affected persons, taking into account their respective rights and obligations in the context of the regulation, to make an informed deployment of AI systems and to gain awareness about the opportunities and risks of AI and possible harm it can cause.
This is not a requirement for technical expertise. It is a requirement for informed competence — that people who work with AI systems understand enough about how those systems function, what they can and cannot do, where their limitations lie, and what risks they present, to use them responsibly in their professional context.
The required level of literacy is proportionate. Article 4 explicitly requires that the assessment be made taking into account the person’s technical knowledge, experience, education, and training, as well as the context in which the AI system is used. A software engineer integrating an AI model needs deeper technical understanding than a sales representative using an AI-powered CRM. A compliance officer needs to understand the regulatory implications of AI use in ways that a front-line employee may not. The obligation is not one-size-fits-all.
Article 4 applies to staff and other persons dealing with the operation and use of AI systems on the provider’s or deployer’s behalf. This includes employees who directly operate or interact with AI systems in their daily work, managers who make decisions about the deployment and use of AI systems, IT staff who integrate, configure, or maintain AI tools, compliance and legal professionals who advise on AI-related regulatory matters, procurement staff who evaluate and select AI systems from vendors, and anyone else who deals with AI systems as part of their role.
The scope is functional, not hierarchical. It captures anyone whose role involves working with AI, regardless of their position in the organisation.
Because the regulation does not prescribe a specific curriculum, certification, or training format, businesses have flexibility in how they implement the AI literacy requirement. The key is that the measures taken are proportionate to the roles involved and the AI systems in use.
For most organisations, a practical AI literacy programme would include several elements. A general awareness component that covers what AI is and how it works at a conceptual level (machine learning, training data, probabilistic outputs), what the AI Act requires and why it matters, the difference between AI capabilities and limitations (including the tendency of AI systems to produce confident but incorrect outputs), ethical considerations in AI use, and the organisation’s own AI policy and governance framework.
A role-specific component that provides deeper training relevant to each person’s function. For users of AI tools, this might cover how to interpret AI outputs, when to override or question AI recommendations, and how to report issues. For managers, it might cover how to assess whether AI deployment is appropriate for a given use case. For IT staff, it might cover data quality requirements, system monitoring, and integration risks. For procurement staff, it might cover what to look for when evaluating AI vendors and what compliance representations to require.
An ongoing update mechanism that keeps training current as AI capabilities, business uses, and regulatory expectations evolve. AI literacy is not a one-time training exercise. The technology moves quickly, and people’s understanding needs to keep pace.
While Article 4 does not explicitly require documentation of AI literacy measures, demonstrating compliance in the event of a regulatory inquiry is much easier if you can show what you did. Effective documentation includes a record of the AI literacy programme — its content, format, and scope; a record of who received training, when, and at what level; an assessment of training needs mapped to roles and AI systems; and evidence of updates and refresher training as circumstances change.
This documentation does not need to be elaborate. A training register, a programme outline, and a periodic needs assessment are sufficient for most organisations. The goal is to show that you took the obligation seriously and implemented measures that were proportionate to your organisation’s size, the AI systems in use, and the roles of the people involved.
Building an AI literacy programme does not require starting from scratch. Many organisations already have compliance training infrastructure — for GDPR, anti-bribery, information security, or other regulatory requirements — that can be extended to include AI literacy.
Step one: conduct a needs assessment. Inventory the AI systems in use across the organisation and identify who interacts with them. Map each role’s AI touchpoints and assess the current level of understanding.
Step two: develop or source training content. The content should cover the general awareness and role-specific elements described above. It can be developed in-house, sourced from external training providers, or assembled from a combination of both. The European Commission and national authorities are beginning to publish guidance materials that can supplement your programme.
Step three: deliver the training. The format should match your organisation’s existing training infrastructure — e-learning modules, in-person workshops, lunch-and-learn sessions, or a combination. The most effective approach for most organisations is a general module for all relevant staff, supplemented by role-specific deep dives for those with more intensive AI involvement.
Step four: document and review. Record participation, gather feedback, and schedule periodic reviews to update the programme as your AI use and the regulatory landscape evolve.
Treating it as a 2026 obligation. AI literacy has been enforceable since February 2025. Waiting for the high-risk system deadline to address it leaves you non-compliant now.
One-size-fits-all training. A generic AI awareness session that treats all staff identically does not meet the proportionality requirement. Training should be calibrated to the person’s role and the AI systems they use.
Training without context. AI literacy training that discusses AI in the abstract without connecting it to the specific AI systems the organisation actually uses is less effective and less likely to satisfy the requirement.
No ongoing component. A single training session delivered once does not constitute a programme. AI capabilities and uses evolve, and literacy must evolve with them.
Ignoring contractors and agents. Article 4 applies to other persons dealing with AI systems on the provider’s or deployer’s behalf — which may include contractors, consultants, and temporary staff. Your programme should consider whether these individuals are within scope.
If you need to build an AI literacy programme or assess your current compliance with Article 4, get in touch or schedule a meeting with our team.
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