AI literacy under Article 4 of the EU AI Act: what companies must do
Article 4 of the EU AI Act requires a sufficient level of AI literacy. What that means in practice, who is affected — and how the Digital Omnibus eases it.
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Among all the obligations of the EU AI Act, one applies broadly and early — and is comparatively cheap to meet: AI literacy under Article 4. It has applied since 2 February 2025, to providers and deployers of AI systems alike.
What does Article 4 require?
Providers and deployers of AI systems must take measures to ensure, to their best extent, a sufficient level of AI literacy among their staff and other people who operate and use AI on their behalf. It is therefore a proportionate best-efforts duty, not a guarantee of a particular outcome. What counts as „sufficient“ depends on the prior knowledge, experience and training of the people involved, on the context the AI is used in, and on who the AI is used on.
AI literacy, as the Regulation defines it, is the skills, knowledge and understanding that allow people to deploy AI in an informed way and to be aware of its opportunities, risks and possible harm.
Who is affected?
Practically every company that uses AI. A „deployer“ is anyone who uses an AI system under their own authority in a professional context — from the marketing team using a text generator to the workshop using an AI-based inspection tool. Purely personal, non-professional use is excluded.
What good measures look like
- Basic training: how AI works, what it can and cannot do, where its limits and risks are.
- Role-specific depth: people who make decisions with AI need more than occasional users.
- Practical rules: what may be entered into which tool, how to handle outputs, when a human has to check.
- Documentation: keep a record of what training happened and who took part.
What the Digital Omnibus changes
Even the original text frames Art. 4 as a proportionate best-efforts duty („to their best extent“) — not a rigid training guarantee. The Digital Omnibus (provisional political agreement of 7 May 2026) additionally foresees relief and simplifications to the AI literacy requirements. That is not yet formally adopted, however; until it is, the original text applies. Anyone who trains sensibly now is on the safe side either way.
AI literacy is the cheapest obligation in the AI Act — and one of the most effective. Teams that understand AI make fewer expensive mistakes.
Frequently asked questions
Since when does the AI literacy duty apply?+
Since 2 February 2025, for providers and deployers of AI systems alike.
Is a single training session enough?+
AI literacy should be kept up over time and adapted to new systems and risks; the measures should be documented. The duty is proportionate — it scales with the role and the context.
Does the Digital Omnibus remove the obligation?+
No. It proposes to ease and simplify the requirements, but it is provisional and not yet in force. The original Article 4 — a proportionate best-efforts duty — still applies.
Author & expert review: Lars Zimmermann · ISO/IEC 42001 Senior Lead Auditor (PECB)
Last updated: 27 May 2026. Researched and reviewed to the best of our knowledge; not a substitute for individual legal advice.
Sources & further reading
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