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EU AI Act Article 4: what the AI literacy duty means for your staff

· EU AI Act

Most of the EU AI Act is about high-risk systems and the companies that build them. Article 4 is different. It applies to almost every organization that uses AI at work in the EU, and it has applied since February 2, 2025.

This article explains what Article 4 asks for and how organizations are meeting it. It is not legal advice; confirm your obligations with your counsel.

What Article 4 says

Article 4 requires providers and deployers of AI systems to take measures to ensure, to their best extent, a sufficient level of AI literacy among their staff and other people dealing with AI systems on their behalf. The measures should take into account those people’s technical knowledge, experience, education and training, the context the AI systems are used in, and the people they are used on.

The Act defines AI literacy (Article 3(56)) as the skills, knowledge and understanding that let people make an informed use of AI systems, and be aware of the opportunities and risks of AI and the harm it can cause.

Who it applies to

  • Providers: organizations that develop an AI system or have one developed and place it on the EU market under their own name.
  • Deployers: organizations that use an AI system in the course of their work. A company whose staff use a generative AI assistant, an AI recruiting tool or an AI feature in their CRM is a deployer.

Because “deployer” covers ordinary business use, Article 4 reaches far beyond technology companies. It can also apply to organizations outside the EU whose AI systems or their output are used in the EU.

What “sufficient” looks like

The Act does not prescribe a course, a test or a number of hours. The European Commission’s guidance points to a risk-based approach: the more an AI system can affect people, and the less technical the people using it, the more training is needed. In practice organizations cover:

  • What AI and generative AI are, and what they are not
  • How to get useful results and check them before relying on them
  • Hallucinations, bias and the need for human review
  • Protecting confidential and personal data when using AI tools
  • The organization’s own AI policy and approved tools
  • AI-enabled threats such as deepfakes, voice cloning and machine-written scams

Role-specific depth matters too. People who choose or configure AI systems, or who use them to make decisions about others, need more than a general introduction.

Keep evidence

Article 4 does not require a certificate, but organizations will need to show what they did if a regulator or customer asks. Keep a record of who was trained, when, on what, and how training is kept current as tools and risks change.

Enforcement

The obligation has applied since February 2, 2025. Supervision and enforcement by national market surveillance authorities apply from August 2, 2026. Even before then, a lack of AI literacy can weigh on how other failures, such as a data breach involving an AI tool, are judged.

How Genbay helps

Genbay’s AI literacy training gives your whole workforce a shared, practical understanding of AI in plain language, as ongoing sessions on one per-seat plan. The Evidence and Total Upskill plans add attendance reports, quizzes and verifiable certificates as your record. For the people who design and run AI oversight, see AI governance.

Sources

This article is general information, not legal advice. Requirements change; check the current text of each framework and confirm your obligations with your auditor or counsel.