AI literacy: who needs training under AI Act art. 4

September 20, 2026 · updated October 1, 2026 · 6 min read · by the aimybusiness team

What Article 4 requires

Article 4 of Regulation (EU) 2024/1689 has applied since 2 February 2025 to providers and deployers of AI systems. In its original wording it required them to ensure, to their best extent, a sufficient level of AI literacy among their staff and anyone using AI systems on their behalf.

The Digital Omnibus (Regulation (EU) 2026/1744, in force since 27 July 2026) rewrote it: providers and deployers must take measures to support the development of AI literacy, without having to guarantee a specific level for each person. It became an obligation of means, not of result. The Commission and member states, in turn, must support these efforts, especially for SMEs.

Why it affects almost every company, not only AI developers

The obligation is not limited to companies that build AI systems: it also covers those that use them in everyday work, whether that is a CRM with built-in predictive features, a writing assistant, or a data-analysis tool. If someone in a company uses one of these tools to do their job, that person falls within the scope of the obligation.

Which measures to take

The regulation does not set one standard programme for everyone: the measures should depend on the person's role, the context they work in, and the risk of the system they use. Someone who routinely uses a system that affects decisions about other people (hiring, credit scoring) needs a deeper understanding than someone using a writing assistant for internal tasks.

Three training levels worth distinguishing

Executive — an understanding of the principles, risks and regulatory obligations, aimed at those who decide where and how the company uses AI.
Operations — informed day-to-day use of the tools: what to check, which mistakes to avoid, and when human oversight is required.
Tech — a more technical understanding for those who build or integrate AI systems, including the compliance implications of technical choices.

Our Academy is structured around exactly these three levels.

How to demonstrate compliance

In the event of an inspection, what matters is being able to document a tracked training path: a plan showing who took part, in what training, when, and with what content, along with periodic updates as the tools in use or the regulatory context change. A single attendance certificate is not enough on its own if it isn't tied to a structured programme consistent with the roles involved.

It can be funded

The AI literacy obligation lends itself well to funding through Italy's joint training funds: we explain how this works in practice in our guide on Fondimpresa.

Frequently asked questions

Q.1Is a one-hour webinar enough to be compliant?

Rarely: after the Digital Omnibus you do not have to guarantee a specific level, but the measures must fit people's roles and the risk of the systems they use. A webinar can be a first step, but it almost always needs to be paired with more targeted training for people who use AI on an ongoing basis, and documented.

Q.2Does the obligation apply to external contractors too?

Yes: the regulation refers to anyone who deals with the operation and use of the system on the company's behalf, not only direct employees.

Q.3What is the risk of not meeting this obligation?

The regulation sets no specific fine for Article 4, but a lack of measures weighs against you in inspections or incidents. The most immediate practical risk is uninformed use of AI tools, leading to operational mistakes that often cost more than the training that would have prevented them.

Sources

This article is for general information only and is not legal advice. For an assessment specific to your company, our team runs a dedicated audit.

Written with the support of artificial intelligence and reviewed by the aimybusiness team, which holds editorial responsibility.

AI literacy: who needs training under Article 4 of the AI Act