EU AI Act Article 4: what does it mean in practice for your organisation?

Updated 1 July 2026. With the Digital Omnibus on AI, adopted by Parliament and the Council in June 2026 but still awaiting publication in the Official Journal, the text of Article 4 is set to be slightly adjusted. The obligation applies in full, as it has since 2 February 2025, but is set to be phrased as: providers and deployers take measures that support the development of AI literacy among their staff. It remains an obligation of means, not an obligation of result: you do not have to guarantee a specific level per individual, but you do have to make demonstrably serious efforts on AI literacy. This article has been adjusted to that phrasing.

Since 2 February 2025, Article 4 of the EU AI Act has been in force. That is the provision requiring organisations to support the AI literacy of their staff. Sounds straightforward. But what does that mean in practice? And what do you, as an employer, HR lead or IT manager, really have to do now?

The core: what does Article 4 say?

The current Article 4 requires providers and deployers of AI systems to take measures, to their best extent, to ensure a sufficient level of AI literacy among their staff and other persons dealing with AI systems on their behalf. Under the Omnibus wording, this is set to become a duty to take measures that support the development of AI literacy. The law specifies that account must be taken of the technical knowledge, experience, education and context of the people who work with AI, and of the context in which the AI systems are used.

That sounds broad, and it is. The legislator has deliberately not drawn up a checklist of "this is exactly what you must do". Instead, Article 4 imposes an obligation of means: you must take appropriate and demonstrable measures to promote AI literacy to the best of your ability. No guarantee that every employee reaches a fixed level, but a serious and defensible approach. The Digital Omnibus made that nuance explicit again in 2026: it is about supporting and promoting, not about a guaranteed level per person.

Why this is not non-committal

The EU AI Act is not a directive but a regulation. That means it applies directly in all EU member states, including Belgium and the Netherlands. No transposition into national law is needed. The obligation applies now.

Yet, this obligation is far from optional. Article 4 itself is not in the AI Act's fine schedule, and so has no EU fine of its own. That does not make compliance optional. National supervisory authorities can, under national rules, impose proportionate penalties or other measures, depending on the specific situation. Moreover, a demonstrable lack of AI literacy counts as an aggravating factor in other infringements of the AI Act.

But let us be honest: the likelihood of a supervisory authority knocking on your SME's door tomorrow is slim. What it is really about is that you as an organisation can demonstrate that you take AI literacy seriously. If something goes wrong, a discriminatory AI decision, a data breach through incompetent use, a complaint from a job applicant, then the first question a supervisory authority asks is: "What have you done to train your staff?"

Who does it apply to?

In short: almost everyone who uses AI tools. And that is broader than you might think.

Does your organisation use Microsoft 365 Copilot? Then you are a "deployer" of an AI system. Do you use an AI tool to screen CVs? Then you are using a high-risk AI system. Does an employee use a free ChatGPT account for work tasks? Then, especially without policy or controls, that can create organisational responsibility and risk.

The law distinguishes between roles, not every employee needs to know the same thing. A receptionist who occasionally uses ChatGPT needs different knowledge than an HR manager who uses AI in recruitment. But both must know what they are doing, what the risks are, and when to raise the alarm.

What "sufficient AI literacy" means in practice

The law does not prescribe which training you must follow or which certificate you must obtain. But from the text and the explanatory notes you can infer what is expected as a minimum:

How do you prove you comply?

Because Article 4 is an obligation of means, it is about demonstrability. You must be able to show that you have taken appropriate measures and made serious efforts on AI literacy. That means:

What you can do now

You do not have to have everything in order tomorrow. But you can start today:

In closing

Article 4 is not a bureaucratic formality. It is an opportunity. An opportunity to help your staff use AI safely and effectively. An opportunity to protect your organisation against risks. And an opportunity to show, as an employer, that you are ahead in a world that is changing ever faster.

The question is not whether you should get to work on this. The only question is: do you start today, or wait until someone calls you out on it?