Executive briefing: EU AI Act
EU AI Act Article 4: What the AI Literacy Requirement Means for Your Organisation
EU AI Act Article 4 requires providers and deployers of AI systems to take measures to support the AI literacy of staff and others who use AI on their behalf. It has applied since 2 February 2025. The July 2026 amendment softened the wording but kept the duty: measures fitted to each role, recorded and reviewed.
Correct as of 28 September 2026. Regulation and guidance change. If you are reading this later, check for updates before relying on it.
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- Article 4 has applied since 2 February 2025. It covers providers and deployers of AI systems generally, not only high-risk AI.
- Regulation (EU) 2026/1744 replaced "ensure, to their best extent, a sufficient level of AI literacy" with "support the development of AI literacy", and added that no specific level has to be guaranteed for any individual.
- The duty was softened, not removed. National market surveillance authorities supervise and enforce it from August 2026.
- No certificate is needed. The European Commission says an internal record of training and guidance is enough to show what you did.
- Deployers of high-risk AI have a separate, harder duty under Article 26: the people overseeing those systems must be trained and competent.
Why the board should care
It is already law
Article 4 has applied since February 2025. The July 2026 amendment changed how the duty is worded, not whether it exists. Every organisation using AI in scope of the Act should be able to show what it has done.
Regulators now supervise it
The Commission says national market surveillance authorities supervise and enforce Article 4 from August 2026. Penalties are set in national law and must be proportionate.
People are where AI goes wrong
Staff who do not understand what an AI tool can and cannot do are the ones who paste in confidential data, trust a wrong answer or miss a biased result.
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FAQ
Frequently asked questions
What is EU AI Act Article 4?
Article 4 is the AI literacy provision of the EU AI Act. As amended in July 2026, it requires providers and deployers of AI systems to take measures to support the AI literacy of staff and others who operate or use AI on their behalf.
What does AI literacy mean?
The Act defines AI literacy as the skills, knowledge and understanding that let people make an informed deployment of AI systems and be aware of AI's opportunities, risks and possible harm. In practice: knowing what a tool can do, where it fails and what you are accountable for.
When did the AI literacy requirement come into force?
Article 4 has applied since 2 February 2025. The Digital Omnibus on AI, Regulation (EU) 2026/1744, in force from 27 July 2026, changed its wording but did not delay or remove it. The Commission says national authorities supervise it from August 2026.
How did the Digital Omnibus change Article 4?
It replaced "ensure, to their best extent, a sufficient level of AI literacy" with "support the development of AI literacy", and added that no specific level has to be guaranteed for any individual. It also added public support for SMEs and AI Board recommendations.
Is AI literacy training mandatory?
Taking measures is mandatory for providers and deployers in scope. The Act does not prescribe a course. Training is the most common measure, but guidance, policy and role-specific support also count, provided they fit the people and the AI systems involved.
Do we need an AI literacy certificate?
No. The European Commission says there is no need for a certificate. Organisations can keep an internal record of training and other guidance. A proportionate record shows who received what, when, and why it suits their role.
What is the fine for breaching Article 4?
Article 4 has no fixed maximum fine in Article 99 of the Act. Each Member State sets penalties in national law, which must be effective, proportionate and dissuasive. National market surveillance authorities enforce it.
Does Article 4 apply to UK companies?
It can. The EU AI Act applies to organisations outside the EU that place AI systems on the EU market, or whose AI output is used in the EU. A UK business serving or employing people in the EU should check its position system by system.
Correct as of 28 September 2026. This content reflects the law, official guidance and deadlines as published on that date. The EU AI Act and its guidance, standards and deadlines are still being amended and clarified. If you are reading this after 28 September 2026, check for later amendments, European Commission guidance and harmonised standards before relying on it. It is general information, not legal advice, and AIPEX accepts no liability for decisions taken on it without specific professional advice.
This briefing is general information about Article 4 of the EU AI Act as amended by Regulation (EU) 2026/1744, correct at the date shown. It is governance guidance, not legal advice. AIPEX is not a certification body and does not certify AI literacy. For decisions about specific AI systems, take advice from a qualified lawyer.