What do the AI literacy requirements of the EU AI Act ask of your company?

What Article 4 says, and what the omnibus changed

Article 4 of the EU AI Act asks providers and deployers of AI systems, companies that build AI and companies that use it, to take measures so that their staff, and others working with AI on their behalf, have a sufficient understanding of it. It has applied since 2 February 2025, one of the first parts of the AI Act to take effect. A deployer is any organisation using AI in its work, so a ten-person firm whose team writes proposals with ChatGPT is one.

In 2026 the Digital Omnibus on AI, Regulation (EU) 2026/1744, amended the article. It entered into force in July 2026. The duty stays, but the omnibus took out the idea of a mandated level: there is no "sufficient" standard you must prove for each person. Instead the Commission and the member states must support companies with practical examples, and the AI Board will adopt recommendations on common objectives. One part did not soften: organisations deploying high-risk AI systems must still make sure the staff who oversee them are trained for that oversight.

Is AI literacy training mandatory?

Not in a fixed form. The Commission's own answers say no specific training, test or certificate is required, and that you do not have to measure what employees know. What is required is that you take measures that fit the situation: the AI you use, the risk involved, and the background of the people using it. Handing over the instructions for use is usually not enough on its own.

Enforcement is expected to bite after an incident rather than on paper. If something goes wrong with AI in your business and you cannot show that the people involved were told how to use it, the absence of training weighs against you.

What sensible AI literacy looks like in a small company

1. List the AI in use. Chat assistants, AI features inside your CRM or office suite, AI in your website's chatbot. Many companies use more than they think.
2. Write down the rules. What staff may put into an AI tool, what not (client data, personal data, confidential numbers), and who checks the output. That is the core of an AI policy.
3. Explain the typical failures. Invented facts and sources, the problem known as AI hallucination; instructions hidden in documents or web pages, known as prompt injection; and outdated answers.
4. Give a short session per role. Sales, finance and support use AI differently. Thirty minutes per team on their own tools teaches more than a generic course.
5. Keep a record. Date, who attended, what was covered, and the policy they received. That record is the cheapest proof of due care you will ever produce.

Which tools are worth using in the first place is covered in AI tools for business, and how to roll them out in implementing AI in your business.

How Article 4 fits the rest of the AI Act

AI literacy is the broadest duty of the AI Act, because it touches almost every company. The other obligations depend on what your AI does. Transparency duties apply to chatbots and generated content, with labelling rules from December 2026; see AI-generated content labelling and the AI Act transparency obligations. High-risk systems carry the heaviest load, and their deadlines moved; see the AI Act high-risk delay. An overview of the whole regulation for a business reader is in the EU AI Act for business, and the EU AI Act checker tells you in a few questions which parts apply to you.