EU AI Act Article 4 AI literacy: what the Commission Q&A and the amended text say

Why this page: the site already covers who the AI Act reaches and what a non-EU supplier owes. Article 4 is the obligation most suppliers meet first, because it applies to ordinary use of AI tools, not only to high-risk systems. This page quotes the Commission’s own Q&A and the Service Desk text. It is not legal advice; see the EU AI Act explainer.

What the amended text says

The AI Act Service Desk publishes Article 4 as amended. Paragraph 1 says 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. It adds that this obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual.

Paragraph 3 says the Board shall adopt recommendations, taking into account European competence frameworks, to support the Commission and Member States in the promotion of AI literacy required under paragraph 1, including by setting out common objectives.

Dates

The Commission’s AI Act page says prohibited AI practices and AI literacy obligations entered into application from 2 February 2025. Its Q&A says the supervision and enforcement rules apply from 3 August 2026 onwards and that the Digital Omnibus amendments to Article 4 entered into force in mid-July 2026. The Commission page gives the date the AI Omnibus entered into force on 27 July 2026. Those two statements differ slightly in wording; check the current text before you cite a date in a contract.

What the Q&A says you do not need

• No certificate: There is no need for a certificate. Organisations can keep an internal record of trainings and/or other guiding initiatives.
• No measurement: Article 4 of the AI Act does not entail an obligation to measure the knowledge of AI of employees.
• No governance structure: No, no specific governance structure is mandated to comply with article 4 of the AI Act.
• No sector-specific rule: No, the AI Office does not impose requirements for specific sectors.

What the Q&A says you should consider

The Q&A lists steps a programme should consider: Ensure a general understanding of AI within their organisation, consider the organisation’s role as provider or deployer, Consider the risk of the AI systems provided or deployed, and then build the literacy actions on that analysis.

On the scope of “other persons”, the Q&A says they are not employees, but persons broadly under the organisational remit and gives examples such as a contractor, a service provider or a client. That is the sentence a prime contractor will use when it asks a subcontractor for evidence.

How a supplier can read this (editorial judgment)

This section is the site’s judgment, not the Commission’s. A buyer who asks for “AI literacy evidence” can reasonably expect a short record: who uses which AI tools, what each role was told about the risks, and when. The Q&A says an internal record is enough, so a request for a third-party certificate goes beyond what the Commission page says. Keep the record next to the audit evidence checklist rather than inventing a separate scheme.

Questions

Does Article 4 apply only to high-risk systems?

No. The Q&A answers that a company whose employees use a general chatbot should be informed about the specific risks, for example hallucination. Deployers of high-risk systems have a further duty: the Q&A says the obligation to ensure that their staff is trained to ensure human oversight remains in place.

Who enforces it?

The Q&A says the supervision and enforcement of Article 4 of the AI Act is not with the AI Office, but it is under the remit of national market surveillance authorities.