AI Literacy Obligation (Art. 4 EU AI Act)

Article 4 of the EU AI Act has required providers and deployers of AI systems since 2 February 2025 to take measures to promote the AI literacy of their staff and of others who deal with AI systems on their behalf. Since the amendment by Regulation (EU) 2026/1744 (in force since 27 July 2026), it is expressly clarified that no particular level of literacy has to be guaranteed. What is meant is a basic technical understanding, an awareness of risk and the ability to review AI output critically. Unlike the obligation to label AI-generated content, this concerns how an organisation itself handles AI tools, not the labelling of content.

In practice

The obligation is addressed to the company as a provider or deployer, not to the individual member of staff – whether a company counts as a provider or as a deployer in a given case depends on how it uses and passes on the AI system. It applies regardless of company size: even a small business using ChatGPT for customer copy can be a deployer. The legislation prescribes no fixed number of training hours; the scope follows the risk of the particular application. Article 4 carries no direct fine – it is absent from the penalty catalogue in Article 99 – but the obligation matters in liability questions: anyone who documents training and usage policies is in a better position after damage caused by misuse of AI than a company with no evidence. The Commission also notes in its FAQ that the supervision and enforcement rules have applied since 3 August 2026. Note on legal status: Article 4 was recast by Regulation (EU) 2026/1744 ("Digital Omnibus on AI", OJ L, 2026/1744 of 24 July 2026) and applies in that version since 27 July 2026. The earlier wording "take measures to ensure, to their best extent" became a pure duty to promote literacy; no particular level of competence is owed. The EU AI Act Service Desk article page still shows (as of 14 August 2026) the wording before that amendment and points this out itself – the consolidated version is the authoritative one.

Matching service

Sources

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