EU AI Act: Article 4 and AI Literacy—What You Need to Know

Thursday, 06 August 2026 at 07:07

Europa versnelt AI-strategie met miljardinvestering en AI-factories

Since 2 February 2025, Article 4 of the European AI Act has been in force. It requires any organization that develops or uses artificial intelligence to ensure staff have enough knowledge to use AI responsibly. The obligation is far broader than many assume: it affects not only AI developers, but also any organization using tools like ChatGPT, Microsoft Copilot, or Google Gemini in daily work. The European Commission considers AI literacy essential for responsible AI use and a key condition for safe adoption within organizations.

What does Article 4 actually cover?

Article 4 is all about AI literacy. In practice, it means organizations must ensure employees understand how AI works, what risks it carries, and how to use it safely and responsibly.

The law applies to both providers (those developing or placing AI systems on the market) and deployers (those using AI systems), who must take appropriate measures. Those measures should match employees’ roles and the risks of the AI systems in use.

What’s explicitly in Article 4?

The official text is short but far-reaching. Lawmakers require organizations to take measures, where reasonably possible, to ensure an appropriate level of AI literacy.

In doing so, they must consider:

the employee’s role;
technical knowledge and experience;
completed courses or training;
the context in which AI is used;
the potential impact of AI on people or groups affected by the system.

That means a software engineer needs different know-how than someone in HR, marketing, or customer support. The AI Act does not impose a one-size-fits-all knowledge level. Organizations must determine what each role actually needs.

Does everyone now have to take an AI course?

No.

A common misconception is that the AI Act mandates certification or a standard training program. It doesn’t.

There is no compulsory course, exam, or certificate. However, the EU expects organizations to show they have thought through responsible AI use and taken suitable steps to train staff. The European Commission also clarifies there is no legally fixed “sufficient level” of AI literacy. It depends on the organization, the AI systems in use, and the associated risks.

In practice, organizations should be able to answer questions like:

Which AI tools do we use?
What risks do these systems pose?
Do employees know which data they may or may not input?
Do they understand that AI can produce errors or so-called hallucinations?
Do they know when human oversight remains necessary?
Are privacy, copyright, and confidential business information properly protected?

How can organizations comply with Article 4?

The AI Act gives organizations flexibility in how they meet this obligation.

Possible measures include:

internal AI training;
workshops;
e-learning;
hands-on exercises;
usage guidelines;
AI policy;
regular awareness sessions;
documentation on responsible AI use.

Most important: the chosen approach must fit employees’ actual work and be visibly embedded in day-to-day AI usage.

A practical example

A marketing team uses ChatGPT daily for blogs, social posts, and emails.

A regulator may then reasonably expect staff to know, among other things:

which business data or personal data must not be entered;
that AI can generate incorrect information;
how to verify AI outputs before publishing;
the rules around copyright;
when human review remains necessary.

For HR, the focus will be on hiring processes, privacy, and discrimination risks. Legal teams will need to prioritize the reliability of legal analysis and document confidentiality.

When did Article 4 take effect?

Article 4 officially took effect on 2 February 2025. From that date, the obligation applies to organizations that develop or use AI.

Since 3 August 2026, national regulators can actively enforce compliance. In 2026, the European Commission also issued additional guidance stressing that the obligation remains fully in force, while allowing organizations to decide how they appropriately implement AI literacy.

Why does Article 4 matter?

Article 4 is arguably one of the most far-reaching provisions of the entire AI Act. While many other rules target only providers of high-risk AI, this obligation touches almost any organization that uses AI.

More and more companies deploy generative AI for marketing, customer support, HR, software development, and back-office workflows. Using such systems alone can be enough to fall under the AI literacy requirement.

That shifts the focus from purely technical compliance to people’s knowledge and skills. Organizations that invest in AI literacy not only reduce legal risk, but also cut the chances of data leaks, poor decisions, and unreliable AI outputs.