DefinitionEU AI Act · Article 4Version 1.023 October 2026
AI literacy and Article 4 of the EU AI Act
Article 4 of the EU AI Act requires providers and deployers of AI systems to take measures to support the development of AI literacy of their staff and of the other persons who operate or use AI systems on their behalf. It has applied since 2 February 2025; its current wording, set by Regulation (EU) 2026/1744 in July 2026, adds that no specific level has to be guaranteed for any individual. This page sets out what changed, who is covered, who enforces it and the records that show the duty is met, read in primary sources on 23 October 2026.
On this page
The duty stayed with the company. Its standard changed.
In this page, "we" means Hikari Blue, which installs AI literacy paths by role as part of the operating layer it runs. Quotations come from Regulation (EU) 2024/1689 and from Regulation (EU) 2026/1744, which amended it; the consolidated text is a documentation tool without legal effect, the Official Journal governs.
Article 4 covers every AI system, not only high-risk ones. It is the first operational duty of the Act to reach most enterprises, and the one a regulator can check first: it asks for measures, and measures leave records.
From "ensure a sufficient level" to "support the development".
The Commission proposed in November 2025 to move the duty from companies to public authorities. The final text did not follow: providers and deployers keep the obligation, with a lighter standard and public support behind it.
| Version | Who carries the duty | What it requires |
|---|---|---|
| Original text · 13 June 2024 | Providers and deployers of AI systems | Take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf. |
| Commission proposal · 19 November 2025 | The Commission and the Member States | Encourage providers and deployers to take measures. The duty on companies would have gone. |
| Text in force · Regulation (EU) 2026/1744 | Providers and deployers, supported by the Commission and the Member States | Take measures to support the development of AI literacy of the same persons, taking into account their knowledge, experience, education and training, the context of use and the persons affected. No specific level has to be guaranteed for any individual. |
Article 4(2) now requires the Commission and the Member States to support providers and deployers, in particular SMEs, and the Commission to publish practical examples of how to comply. Article 4(3) asks the AI Board to adopt recommendations based on European competence frameworks.
The definition did not change. Article 3(56) defines AI literacy as the skills, knowledge and understanding that allow providers, deployers and affected persons to make an informed deployment of AI systems and to gain awareness of their opportunities, risks and possible harm.
Anyone who operates or uses an AI system on your behalf, employee or not.
Staff
Everyone in the organization directly dealing with an AI system, from the executive who approves a use case to the employee who drafts with an assistant.
Other persons
People under the organization's remit who are not employees. The Commission's Q&A names a contractor, a service provider or a client as examples.
Companies outside the EU
The Commission states that Article 4 applies inside and outside the EU as long as the AI system is placed on the Union market, used in the Union or has an impact on people located in the EU.
Deployers of high-risk systems
Article 26(2) adds a separate duty: human oversight is assigned to persons with the necessary competence, training and authority. It applies from 2 December 2027 for Annex III systems.
In application since February 2025, supervised since August 2026.
| Date | What happens | Source |
|---|---|---|
| 2 February 2025 | Chapters I and II apply, Article 4 included. | AI Act, Article 113(a) |
| 27 July 2026 | Regulation (EU) 2026/1744 enters into force; the new wording of Article 4 replaces the old one. | Regulation (EU) 2026/1744, Article 4 |
| 2 August 2026 | National market surveillance authorities start supervising and enforcing, AI literacy included. | Commission, AI Act Service Desk timeline |
| 2 December 2027 | Deployers of Annex III high-risk systems assign oversight to trained, competent persons. | AI Act, Articles 26(2) and 113(c) |
Penalties. Article 99 sets no specific fine for Article 4. Member States lay down the penalties under Article 99(1), and the Commission states that national authorities could impose penalties and other enforcement measures for infringements of Article 4, case by case and proportionately.
This is not legal advice. Which authority supervises a given company depends on the Member State.
No certificate. A dated record per person, tied to the systems they use.
The Commission states that no certificate is needed and that organizations can keep an internal record of trainings and other guiding initiatives. It also warns that asking staff to read the instructions for use is, in many cases, not enough.
Our governance framework turns that into one control, GOV-E-02: every person who operates or verifies holds a dated, role-resolved literacy record before access is granted, linked to the identities in the agent and operator registers and refreshed annually.
| Role | What the person must be able to do | Record |
|---|---|---|
| Executives and board | Read an AI proposal, judge whether its trade-offs are defensible, and sign off on a no-go for the right reason. | Dated session record, with the systems and decisions in scope. |
| Workflow owners and managers | Know where AI fits in the team's workflow and where it does not, measure real use, escalate a failure without cover-up. | Record linked to the workflows they own. |
| Operators and verifiers | Check an output before acting on it, approve or reject at the gate, stop the system. | Record linked to their identity, required before access. |
| All staff using AI tools | Use approved tools, know which data must never leave the perimeter, check an output before relying on it. | Dated record per person, refreshed annually. |
| Contractors and service providers | The skills their task requires, same as employees. | Contractual clause and record, or the provider's own record on request. |
Competencies by role are those of our acculturation paths, under 3 mastery layers: AI Literacy, AI Operating Discipline, AI Workflow Ownership. The Commission's living repository of AI literacy practices is a source of examples; replicating them does not, by itself, give a presumption of compliance.
The questions asked about Article 4.
Is AI literacy mandatory under the EU AI Act?
Yes. Article 4 requires providers and deployers of AI systems to take measures to support the development of AI literacy of their staff and of other persons acting on their behalf. It has applied since 2 February 2025, and national market surveillance authorities supervise it since August 2026.
Did the Digital Omnibus remove Article 4?
No. The Commission proposed in November 2025 to turn it into a duty of public authorities to encourage literacy. Regulation (EU) 2026/1744 kept the duty on providers and deployers, replaced "ensure a sufficient level" with "support the development", and stated that no specific level has to be guaranteed for any individual.
Do we need a certificate or an external training?
No. The Commission states that no certificate is needed and that an internal record of trainings and other guiding initiatives can document the measures. Its AI Act Service Desk adds that there is no obligation for external training or certification.
Who must be covered?
Staff who deal with AI systems and other persons acting on the organization's behalf, such as contractors, service providers or clients. Measures can differ by role, knowledge and context of use.
Does Article 4 apply to companies outside the EU?
Yes, when the AI system is placed on the Union market, used in the Union or has an impact on people located in the EU, according to the Commission. A Swiss or US company in that position carries the same duty.
What are the penalties?
Article 99 sets no specific amount for Article 4; Member States set the penalties. The Commission says enforcement is proportionate, case by case, and that a sanction becomes more likely when an incident traces back to missing training or guidance.
Reference documents and primary sources.
Every quotation, date and statement of the Commission on this page comes from the sources below, read on 23 October 2026.
Reference documents
- AI acculturation Paths by role and business line, with dated, role-resolved training records.
- Enterprise AI Governance Framework v1.0 15 controls with owners, cadences, evidence and EU AI Act hooks. CC BY 4.0.
- AI Operating Layer Reference Architecture v1.0 4 planes, 4 testable controls and the 9-field record.
- AI audit trail: definition and EU AI Act mapping The 9 fields of the record, mapped to Articles 12, 19 and 26.
Primary sources, consulted on 23 October 2026
- Official Journal · Regulation (EU) 2026/1744, Digital Omnibus on AI (opens in a new tab) Regulation of 8 July 2026, published on 24 July 2026. Article 1(5): new Article 4.
- Official Journal · Regulation (EU) 2024/1689, original text (opens in a new tab) Articles 3(56), 4, 26(2), 99 and 113 as adopted on 13 June 2024.
- EUR-Lex · COM(2025) 836, Digital Omnibus on AI proposal (opens in a new tab) Commission proposal of 19 November 2025, with the version of Article 4 that was not adopted.
- European Commission · AI Literacy, Questions & Answers (opens in a new tab) Last updated 27 July 2026: scope, documentation, enforcement by national authorities.
- European Commission · AI Act Service Desk, implementation timeline (opens in a new tab) Enforcement from 2 August 2026, AI literacy included.
- European Commission · Living repository of AI literacy practices (opens in a new tab) Published on 4 February 2025, updated 10 August 2026. Examples, without presumption of compliance.
How to cite this document.
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Preferred citation
Hikari Blue, "AI literacy and Article 4 of the EU AI Act v1.0", 23 October 2026, https://hikariblue.com/glossary/ai-literacy-article-4
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Changelog
v1.0 · 23 October 2026. First public version.
Editorial correction · 25 October 2026: license extended to this page (CC BY 4.0).
License. Published under CC BY 4.0: free to cite, quote and reuse with attribution to Hikari Blue and a link to this page. The license covers Hikari Blue’s text, tables and diagrams on this page; it does not cover third-party data, quotations or legal texts, which keep their own terms, nor the Hikari Blue name and logo, trademarks of UNITED4 LLC.
Check your Article 4 records against your AI estate.
30 minutes with a named partner. We take the AI systems your teams use today and the training records you hold, and show which roles are covered, which are not, and which record a regulator would ask for first. You leave with the gap list, whether or not we work together.
- Your AI systems, mapped to the roles that use them
- The records you hold, and those that are missing
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