AI Risk Practice For organisations

EU AI Act · AI literacy ·

What Article 4 of the EU AI Act asks of organisations now

Article 4, the AI literacy rule, was amended in July 2026. This page gives the new text word for word and sets out what the European Commission says organisations should do. Every quote is checked against the Official Journal and the Commission's own Q&A.

The short answer

  • If your organisation provides or uses AI systems, you must take measures to support the AI literacy of your staff and others using AI on your behalf.
  • The measures should suit people's knowledge, experience and training, and the context the AI is used in. No specific level of literacy is required.
  • No certificate is needed. The Commission says an internal record of training is enough.
  • The duty has applied since 2 February 2025. National market surveillance authorities supervise and enforce it from August 2026.

The text, word for word

"Providers and deployers of AI systems shall take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be used. This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual."

Article 4(1) of Regulation (EU) 2024/1689, as replaced by Regulation (EU) 2026/1744, Article 1(5)

Paragraphs 2 and 3 are aimed at public bodies. The Commission and the Member States must support organisations, "in particular SMEs", and the Commission must publish practical examples of how to comply. The AI Board must adopt recommendations that set common objectives.

What changed in July 2026

The original Article 4 asked organisations to ensure a "sufficient" level of AI literacy. The Digital Omnibus on AI, Regulation (EU) 2026/1744, replaced that with a duty to take measures that support it. In the Commission's words, AI literacy remains an obligation, "but no specific – or ‘sufficient’ - level is mandated".

"Article 4 of Regulation (EU) 2024/1689 should be amended to require providers and deployers to take measures to support the development of AI literacy of their staff and of other persons dealing with the operation and use of AI systems on their behalf."

Regulation (EU) 2026/1744, recital (8)

One duty did not soften. The Commission notes that "for those who deploy high-risk AI systems, the obligation to ensure that their staff is trained to ensure human oversight remains in place" (Article 26).

The dates

DateWhat happenedSource
2 Feb 2025Article 4 starts to applyCommission Q&A
8 Jul 2026Regulation (EU) 2026/1744 signed at StrasbourgOfficial Journal text
24 Jul 2026Published in the Official Journal (OJ L, 2026/1744)EUR-Lex
27 Jul 2026Commission updates its AI literacy Q&ACommission Q&A
Aug 2026National market surveillance authorities supervise and enforce Article 4Commission Q&A (it gives both 2 and 3 August)

What the Commission says to consider

The Commission's Q&A lists the steps an AI literacy programme should consider "at least":

  1. A general understanding of AI across the organisation: what it is, how it works, what AI you use, and its opportunities and dangers.
  2. Your role: whether you develop AI systems (provider) or use systems made by others (deployer).
  3. The risk of the systems you use: what staff need to know, which risks they should be aware of, and how to reduce them.
  4. Measures built on that analysis, taking account of people's knowledge, experience and training, and the context and purpose of each system.

Paraphrased from the Commission's AI Literacy Q&A, "Compliance with article 4". It also encourages links to the AI Act itself and to ethics and governance.

Questions people ask

Do we need a certificate to show we comply?

No. The Commission's answer is: "There is no need for a certificate. Organisations can keep an internal record of trainings and/or other guiding initiatives."

Do we have to test or measure what staff know?

No. The Commission says Article 4 "does not entail an obligation to measure the knowledge of AI of employees", and the amended text does not require any specific level of literacy.

Does it apply if staff only use tools like ChatGPT?

Yes. Asked about staff using ChatGPT to write or translate text, the Commission answered: "Yes, they should be informed about the specific risks, for example hallucination."

Is a training course mandatory?

Not as such: "no strict requirements or mandatory trainings are imposed." But the Commission warns that simply asking staff to read a system's instructions "might be ineffective", and that measures should suit each group.

Are there extra rules for financial services or healthcare?

No. The Commission sets no sector-specific requirements, but each AI system's sector, purpose and risk should still shape what you do.

Do we need an AI officer or a governance board?

No. The Commission says "no specific governance structure is mandated to comply with article 4".

Who enforces Article 4?

National market surveillance authorities in each Member State, from August 2026. The Commission's AI Office does not enforce it.

Where to start

These are our suggestions as AI risk practitioners, not legal requirements. They follow the Commission's steps and are easy to keep on record.

  1. List the AI tools in use, including the ones people use on their own, and who uses each.
  2. Give everyone a short baseline on judgement: what to check, what not to share, and when to report.
  3. Add role-specific steps where the risk is higher, and the human-oversight training Article 26 requires for high-risk systems.
  4. Keep a dated record of what you provided and to whom. Note what changed since last time.
  5. Review it when your tools change, and at least once a year.

Our 26-minute module is designed to be one of those measures for all staff, with a dated record of what you deployed. See how it works or play the demo.

Sources, checked 16 October 2026

General information about the regulation, not legal advice. Check the current text before relying on it.