Article 4

AI literacy

In force since 2 February 2025

Article 4 binds every provider and deployer of AI systems, with no exemption for small companies, and it has applied since 2 February 2025. It was also rewritten last month, and the new version asks for less than the old one did.

What it requires

Take measures supporting the development of AI literacy among the staff who operate AI systems on your behalf, and among others who deal with their operation for you.
Take account of those people's technical knowledge, experience, education and training, and of the context the systems are used in.
Nothing more specific than that. The article names no curriculum, no minimum hours, no certificate and no register.

Who it applies to

Any provider or deployer of an AI system. Since AI features now arrive inside ordinary business software without anyone asking for them, that reaches most organisations.
There is no exemption by headcount or turnover. A five-person firm whose staff use ChatGPT is in scope.
It binds the organisation rather than the individual. The duty is to take measures, not for any particular employee to reach a standard.

What changed in July 2026

Regulation (EU) 2026/1744, the Digital Omnibus, replaced Article 4 outright with effect from 27 July 2026.
The previous text required providers and deployers to ensure a sufficient level of AI literacy. The current text requires them to take measures to support its development.
The new article says expressly that no specific level of AI literacy has to be guaranteed for any given individual.
The duty is therefore one of means and not of result. What you can be asked to show is what you did, not what anyone learned.
None of this changed the commencement date. Article 4 has applied since 2 February 2025, and national market surveillance authorities have been able to enforce it since 2 August 2026.

What most guidance still gets wrong

Almost everything written about Article 4 before August 2026 describes the repealed version, and tells companies to guarantee competence, test staff or certify them. That is more than the article now asks, and the sites saying it have not noticed.
The second error is treating this as a course to be bought. The article asks for measures appropriate to the people and the context, which for a small team is usually a written policy, a briefing that actually happened, and a record showing it did.
Both mistakes are expensive in the same direction, which is worth knowing before anyone sells you a training package to fix a duty that no longer exists in that form.

Which of these apply to you?

Ten questions, about three minutes, no account and nothing stored on our side. It tells you which of these obligations reach your organisation and which dates you are already past.

Start the free assessment

Written against Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744. Not legal advice. Every change to this drafting is dated and published on the change history page.