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What is AI literacy? Definition and the AI Act Article 4 obligation
AI literacy means the skills, knowledge and understanding that allow people to use AI systems in an informed way and to be aware of their opportunities, risks and possible harms. Since 2 February 2025, Article 4 of the AI Act has required every organisation that provides or deploys AI to take measures to develop it among its staff, without prescribing a standard training course or a certificate.
The AI Act (Regulation (EU) 2024/1689) defines AI literacy in Article 3, point 56. Article 4 has applied since 2 February 2025 to all providers and deployers, whatever the risk level: an SME whose staff use a conversational assistant is covered. In its original version, it required organisations to ensure a “sufficient level” of AI literacy. The Digital Omnibus regulation (EU 2026/1744, in force since 27 July 2026) reworded it: the obligation remains, but no specific level is prescribed, and organisations must take measures to support AI literacy. The Commission and Member States must in turn publish practical examples, and the European AI Board will adopt recommendations. In its FAQ, the Commission states that no mandatory training in the strict sense is imposed, that no certificate is required and that an internal record of the actions taken is enough as evidence. It adds that pointing staff to the tools' instructions for use is not sufficient. Enforcement lies with national market surveillance authorities from August 2026, with penalties set by national law and proportionate to the seriousness of the infringement. For deployers of high-risk systems, the separate obligation to train the people in charge of human oversight remains in full.
Concrete example
Illustrative case. A 60-person accounting firm in Nantes rolled out Microsoft Copilot to all staff. Its Article 4 approach fits on one page: a one-hour session for everyone (what an LLM is, hallucinations, data never to enter), a two-hour module for engagement managers who review generated notes, a signed usage charter, and a table dating each action. If the supervisory authority or a client asks, the firm shows that table. None of this requires a certified body.
Comparison
| Point | Original version (2024) | Amended version (Regulation 2026/1744) |
|---|---|---|
| Obligation | Take measures to ensure a sufficient level of AI literacy | Take measures to support the development of AI literacy |
| Required level | “Sufficient level”, undefined | No specific level prescribed |
| Role of public authorities | Not set out in Article 4 | Commission and Member States publish examples; the European AI Board adopts recommendations |
| Application | 2 February 2025 | 2 February 2025 (unchanged) |
| Enforcement | National market surveillance authorities | National authorities, from August 2026 |
FAQ
Is AI training mandatory?
The obligation exists, but it does not take the form of prescribed training. Since 2 February 2025, Article 4 of the AI Act has required organisations that provide or use AI to take measures to develop their staff's AI literacy. Since the Digital Omnibus (July 2026), no specific level is required. The Commission states that no standard training is imposed: awareness sessions, internal guides, workshops or courses are all possible, adapted to the tools and risks. Doing nothing, or relying only on instructions for use, is not compliant.
What is AI literacy?
It is the ability to use AI in an informed way: knowing how a tool works, what it does well, where it gets things wrong, which data not to share with it and what harm it can cause.
What does Article 4 of the AI Act say?
As amended by Regulation 2026/1744, it requires providers and deployers of AI systems to take measures to develop the AI literacy of their staff and of other persons using those systems on their behalf. It also asks the Commission and Member States to support these efforts, including through practical examples, and the European AI Board to adopt recommendations.
Who is covered by the AI literacy obligation?
Any organisation that provides or deploys an AI system, whatever its size and whatever the risk level. On the people side, it covers employees who use or configure AI, but also contractors or temporary staff using it on the organisation's behalf.
Is a certificate or an accredited body needed?
No. The Commission states that no certificate is needed and no specific governance structure is required. An internal record of training and support actions is enough to keep track.
What are the penalties for non-compliance?
The AI Act sets no specific fine for Article 4. National market surveillance authorities have supervised it since August 2026, with penalties laid down in national law and proportionate. According to the Commission, a penalty is more likely if an incident results from a lack of training or guidance for staff.
See also
Further reading
Living repository of AI literacy practices, European AI Office
Sources
- Regulation (EU) 2024/1689 on artificial intelligence (AI Act), Article 3(56) and Article 4. https://eur-lex.europa.eu/eli/reg/2024/1689/oj
- Regulation (EU) 2026/1744 (Digital Omnibus on AI), amending Article 4. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R1744
- AI Literacy, Questions & Answers, European Commission, July 2026 update. https://digital-strategy.ec.europa.eu/en/faqs/ai-literacy-questions-answers