Article 4 of the EU AI Act, applying since 2 February 2025, requires providers and deployers to take measures to support AI literacy among their staff and others who use AI on their behalf. It does not require a guaranteed literacy level, but you should be able to show what you did and why it fit.
What the text says
Providers and deployers must take measures to ensure, to their best extent, a sufficient level of AI literacy among staff and other people dealing with the operation and use of AI systems on their behalf. The measures should take into account their technical knowledge, experience, education and training, the context the systems are used in, and the people affected.
The text also says the obligation does not require providers or deployers to guarantee any specific level of literacy. The page we read marks paragraphs 2 and 3 as new, giving the Commission and Member States a role in supporting SMEs and the Board a role in recommendations, so check the official text for the exact amended wording.
Who counts
Not just engineers. Anyone who operates or uses AI systems for you: a recruiter using a screening tool, a customer agent using a drafting assistant, a contractor with access to a model. Include them in scope.
A proportionate plan
- Inventory AI use. List the systems and who uses them.
- Group users by role and exposure: builders, operators, occasional users.
- Set a baseline for everyone: what AI systems can get wrong, what data not to paste in, who to tell when output looks harmful.
- Add role specific content: builders learn about data quality, evaluation and security; operators of high-risk systems learn oversight and automation bias.
- Record completion, dates and content versions.
- Refresh when tools or uses change.
Content that earns its time
Short, concrete material works better than a long slide deck. Cover how the specific tools you use behave, real failure modes such as confident but wrong output, the company rules for data and approvals, and how to escalate. Tie it to the context of use, as the article asks.
Evidence
A regulator or customer asking about Article 4 will want to see that you took measures that fit your situation. Keep:
- The AI inventory.
- The training plan by role.
- Attendance or completion records.
- The materials, with dates.
- A note on how the plan fits your risk.
What not to do
Do not buy a certificate for everyone and call it done, and do not promise a competence level in contracts. The article stops short of that, and a promise you cannot verify is a liability.
Quick check
Must I certify employees as AI literate?
No. The duty is to take measures supporting a sufficient level, with no guarantee of a specific level required.
Does Article 4 apply to small companies?
Yes, to providers and deployers of any size. Support for SMEs is addressed in the newer paragraphs, but the duty itself remains.
Sources
- AI Act Article 4, AI literacy (an unofficial reader; confirm wording against the Official Journal)
- European Commission, AI Act regulatory framework
Last reviewed: 19 October 2026.
