Article 4 of the EU Artificial Intelligence Act (EU AI Act) has applied since 2 February 2025. It requires companies that provide or use AI systems to take measures on the AI literacy of their staff. That is why many articles talk about an "AI training requirement". This post explains what is behind it and how to meet the requirement pragmatically.
Note: This post is not legal advice. It reflects the law after the Digital Omnibus on AI (Regulation (EU) 2026/1744, in force since 27 July 2026). Check the current wording on EUR-Lex or with your legal counsel.
Who does Article 4 apply to?
The obligation applies to providers and deployers of AI systems. A deployer is anyone who uses an AI system under their own authority in a professional context. That covers most companies as soon as employees use tools such as ChatGPT, Microsoft Copilot, translation services or AI features in business software.
Company size does not matter, and neither does whether a system is classified as high-risk. Using a chat assistant in the office is enough.
What does AI literacy mean?
The regulation defines AI literacy as the skills, knowledge and understanding needed to deploy AI systems in an informed way and to be aware of the opportunities, risks and possible harm. Staff's technical knowledge, experience, education and training, as well as the context in which the AI systems are used, should all be taken into account.
In practice, this means there is no one-size-fits-all curriculum. A developer integrating a language model into an application needs different knowledge than a sales rep who drafts emails with AI.
What did the Digital Omnibus change?
The Digital Omnibus on AI, Regulation (EU) 2026/1744, rewrote Article 4 in July 2026 but did not remove it. Instead of having to ensure "to their best extent" a sufficient level of AI literacy, providers and deployers must now take measures to support the development of AI literacy among their staff. The new text states explicitly that they do not have to guarantee a specific level of AI literacy for any individual.
So the duty to act remains. What is also new: the Commission and the Member States are to support companies in meeting the obligation, in particular SMEs, and the Commission will publish practical examples. The regulation does not prescribe a specific certificate or a fixed number of training hours.
Five steps to AI literacy in your company
1. Map your AI use
List the AI tools used in your company, both official and unofficial. Note who uses them, for what, and which data they process.
2. Define roles and needs
Group your staff by context of use, for example everyday office users, departments handling sensitive data, development and IT, and management. For each group, decide what they need to know.
3. Run AI literacy training
For most users, a compact introductory session is enough: How do generative AI models work, where are their limits, which data may be entered, and how do you check the results? For specialist departments and developers, in-depth formats pay off.
4. Set clear rules
A short AI policy creates clarity: Which tools are approved, which data is off-limits, and who to ask when in doubt?
5. Document and refresh
Record who took part in which measure and when. AI tools change quickly, so plan regular refreshers, for example once a year or whenever a new tool is introduced.
How DFT IT can help
In our EU AI Act training, teams learn the basics of generative AI, the risk categories of the AI Act and how to use AI tools safely at work, all in one day. You will find more courses in our training overview. If you have questions about your situation, get in touch.