Article 4 is the only obligation in the AI Act that falls on every provider and every deployer of AI systems, whatever the risk level of those systems, subject, like the rest of the Regulation, to the exclusions in Article 2: purely personal non-professional use; scientific research and development; research, testing and development before placing on the market or putting into service, real-world testing excepted; military, defence or national security purposes; and systems released under free and open-source licences, unless they are placed on the market or put into service as high-risk systems or fall under Article 5 or 50. It has been enforceable since 2 February 2025, and its current wording dates only from 27 July 2026.
The obligation has existed since 2 February 2025. But the text you read today is not the text that applied then: Regulation (EU) 2026/1744 replaced Article 4 in full, and its new wording has only been in force since 27 July 2026. Quoting today’s version and dating it to February 2025 is an anachronism of seventeen months, and it matters, because what was added is a limit that works in favour of organisations.
What exactly does Article 4 say?
It asks for measures, not for a result, and its current wording dates from July 2026. Providers and deployers must take measures to support AI literacy among their staff and anyone operating systems on their behalf — and the text adds that this does not oblige them to guarantee any specific level for any individual.
“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.”
Source: Article 4(1), consolidated version of 27 July 2026
What does AI literacy actually require?
Measures, not a result. The verb is “shall take measures to support the development of”. Not “shall train”. Not “shall ensure”.
A scope wider than staff. The obligation covers staff and “other persons dealing with the operation and use of AI systems on their behalf”. Contractors and subcontractors are within it.
Proportionality on four factors. Technical knowledge, experience, education and training of the people concerned, and the context the systems are to be used in. To which the text adds consideration of “the persons or groups of persons on whom the AI systems are to be used”, those on the receiving end.
And a limit, added in 2026. The last sentence is the one to quote whenever a vendor offers a mandatory AI literacy certification.
Is a certified training course required, and how many hours?
Neither: the text sets nothing of the kind. The Commission’s own FAQ, updated after the omnibus, puts it plainly: “There is no need for a certificate”.
It sets no number of hours, no syllabus, no frequency, no accredited body, no certificate. Any page, offer or quotation that asserts one has left the text, and ought to say so.
The Commission’s official FAQ, updated on 27 July 2026 after the omnibus, is blunt about it: “There is no need for a certificate”. That FAQ is an interpretative document and is not binding.
What did the omnibus change in Article 4?
Three things, and the most visible is not the most certain. Paragraph 1 was rewritten, and two paragraphs were added.
Paragraphs 2 and 3 are new, and they bear on no company. Paragraph 2 tasks the Commission and the Member States with supporting providers and deployers, “in particular SMEs”, and requires the Commission to publish practical examples on the single information platform of Article 62. Paragraph 3 tasks the AI Board with adopting recommendations, “taking into account European competence frameworks” and “including by setting common objectives”. Neither existed before 27 July 2026.
On paragraph 1, the earlier wording appears more demanding, and it pays to be precise about what changed. Only an indirect record of it survives in our sources: the Commission’s guidelines on prohibited practices, which predate the omnibus, report that Article 4 “prescribes AI literacy measures for providers and users of AI systems to ensure ‘a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems’”.
The mechanism was therefore already one of measures. What differs is the objective attached to them — ensuring a sufficient level — and the absence of any limit of the kind now in the last sentence.
We draw no compliance conclusion from that. The exact text of Article 4 as it applied on 2 February 2025 has not been retrieved from the Official Journal, and we know it only through that indirect record.
Two instruments not to confuse with the text
The Commission’s FAQ is interpretative support, not binding. It is useful, and it was rewritten after the omnibus.
The AI Pact is a voluntary pledge, predating the Regulation becoming applicable, and its official page cites neither an article nor a recital of the text. It is not a way of performing Article 4, and presenting it as one is misleading.
One further point, rarely made: the draft guidelines on Article 50 indicate that the Article 4 literacy requirements “also apply to both providers and deployers of AI systems within the scope of Article 50 AI Act”. That is the only institutional source known to make the connection, and the document is not adopted.
What happens if you do nothing about AI literacy?
Article 4 is not listed among the provisions in Article 99(4), so it carries no ceiling of its own. Member States determine the regime under Article 99(1), and must “take into account the interests of SMEs, including start-ups, and SMCs, and their economic viability when imposing penalties”.
A timing point is worth flagging: the obligation has run since 2 February 2025, while the penalty regime in Chapter XII has only applied since 2 August 2025. Six months separate the obligation from its penalty.
What this page rests on
Article 4 of Regulation (EU) 2024/1689 in the wording given to it by Regulation (EU) 2026/1744, consolidated version of 27 July 2026, the authentic text remaining the one published in the Official Journal. The Commission’s official AI Literacy Questions and Answers, updated on 27 July 2026. Articles 2, 99 and 113 for scope, penalty and dates. The draft guidelines on Article 50, point (25), whose content was approved on 20 July 2026: not adopted, non-binding, English only, quoted as they stand. The regime in force before 27 July 2026 is described only through an indirect record, and that reservation is stated in the body of this page.
Sources. Regulation (EU) 2024/1689, consolidated text of 27 July 2026 and Regulation (EU) 2026/1744, both consulted on 27 August 2026. The Commission’s page on the guidelines on the transparency obligations in Article 50, consulted on the same date.
Frequently asked questions
Does the AI Act require training every employee?
No. The text requires taking measures to support the development of AI literacy (measures, not a result) and to do so taking into account the technical knowledge, experience, education and training of the people concerned and the context the systems are to be used in. It sets no number of hours, no syllabus, no frequency and no accredited body.
Is a certificate required?
No, and the text says so itself since it was rewritten: the obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual. The Commission’s official FAQ, updated on 27 July 2026, puts it more bluntly still: there is no need for a certificate. That FAQ is an interpretative document and is not binding.
Since when does this obligation apply?
Since 2 February 2025. But there is a nuance almost nobody makes: the current wording of Article 4 has only been in force since 27 July 2026, the date Regulation (EU) 2026/1744 entered into force and replaced it in full. Quoting today’s text and dating it to February 2025 is an anachronism of seventeen months.
What is the penalty for not complying?
Article 4 is not listed in Article 99(4), so it carries no ceiling of its own. Member States set the penalty regime under Article 99(1), taking into account the interests of SMEs and small mid-cap companies. Note the timing: the obligation has applied since 2 February 2025, while the penalty regime of Chapter XII has only applied since 2 August 2025.
This content is a technical and regulatory information resource. It does not constitute legal advice.