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AI literacy (Article 4): what training the AI Act requires and how to document it

28 October 2026 · Sources checked on 28 October 2026.

Article 4 of the EU AI Act (Regulation (EU) 2024/1689) is one of the first provisions of the Regulation to apply: it is in Chapter I, which has applied since 2 February 2025 (Article 113, third paragraph, point (a)). It is addressed to providers and deployers of AI systems. An SME that uses third-party AI tools in its professional activity is a deployer (Article 3, point (4)), so the Article also speaks to it, whatever its size.

Regulation (EU) 2026/1744 (the "Digital Omnibus on AI"), of 8 July 2026 and published in the Official Journal on 24 July 2026, replaced Article 4 with a new text (its Article 1, point (5)), in force since 27 July 2026. This article summarises the official text as it applies today; it does not interpret and it does not constitute legal advice.

What Article 4 says today

What AI literacy means is set out in Article 3, point (56): "skills, knowledge and understanding that allow providers, deployers and affected persons, taking into account their respective rights and obligations in the context of this Regulation, to make an informed deployment of AI systems, as well as to gain awareness about the opportunities and risks of AI and possible harm it can cause".

What Regulation (EU) 2026/1744 changed

Original text (2024)Text in force (since 27 July 2026)
What is requiredTake measures to ensure, to their best extent, "a sufficient level of AI literacy" of staff and other persons operating the systems on their behalfTake measures "to support the development of AI literacy" of those same persons
Level to be reachedA "sufficient level"No specific level of any individual is required
Public supportNot in Article 4The Commission and the Member States support providers and deployers, in particular SMEs, and the Commission publishes practical examples (paragraph 2)
Criteria for choosing the measuresTechnical knowledge, experience, education and training; context of use; persons on whom the systems are usedThe same
Since when2 February 2025Article 4 still applies from 2 February 2025; the new wording has applied since Regulation (EU) 2026/1744 entered into force, on 27 July 2026

Recital 8 of Regulation (EU) 2026/1744 gives the reason: experience shared by stakeholders shows that imposing stringent obligations to ensure a sufficient level of AI literacy would not be suitable for all types of providers and deployers, and that such obligations create an additional burden, particularly for smaller enterprises. The obligation to take measures remains; the new text no longer refers to a "sufficient level" and states expressly that no specific level of any individual is required.

What training it requires

Article 4 sets no courses, hours, contents or qualifications. What it does set:

High-risk systems carry a requirement of their own: Article 26(2) requires deployers to assign human oversight to natural persons "who have the necessary competence, training and authority, as well as the necessary support". It applies from 2 December 2027 for Annex III systems and from 2 August 2028 for Annex I systems (Article 113, third paragraph, point (c)).

How to document it

Article 4 does not require a register or a specific format. Recording which measures were taken, when, for whom and for which systems is how they can be shown and reviewed. An orderly way to do it:

  1. List the AI systems the company uses (including those built into another product) and who operates them.
  2. For each group of people, decide which measure fits their experience and their use: someone drafting with an assistant is not in the same position as someone reviewing job applications with a screening tool.
  3. Record each activity: what it was, date, type (course, session, guide), participants and the systems it refers to.
  4. Keep the evidence: the attendance sheet, the guide published on the intranet, the course attendance record.
  5. Repeat when a new system arrives, the use of one changes or someone joins who will operate it.

The AI Inventory template comes with this record ready: the "AI literacy (Art. 4)" database has the columns "Activity", "Date", "Type" (Course, Session, Internal guide, Other) and "Participants", and each activity is linked to the systems it refers to, which show it in their "Training" column; the evidence goes in the "Evidence" database with the type "Training". Article 4(1) is preloaded in "Deployer obligations", with its summary, the date from which it applies, the link to EUR-Lex and the date it was checked: AI Inventory.

Sources (opened on 28 October 2026)

Document organisation tool based on official texts; it does not constitute legal advice.

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