AI literacy: the obligation under Article 4 of the EU AI Act

Of all the obligations in the EU AI Act, there is one that already applies and affects almost every organization: the AI literacy requirement under Article 4. This obligation has been in force since 2 February 2025, together with the ban on certain AI practices. Yet it is the least noticed requirement of the entire regulation, while it has the broadest reach.

What the law requires

Article 4 requires providers and deployers of AI systems to take measures that ensure a sufficient level of AI literacy, both among their own staff and among other persons dealing with the operation and use of AI systems on their behalf. The law does not prescribe a specific training, exam, or certificate. It does expect the measures to match the technical knowledge, experience, and context of those involved, and the systems they work with.

This means the implementation differs per role. A data scientist who develops models needs a different level of literacy than a customer service employee operating an AI chatbot, who in turn needs a different level than a director deciding on AI investments. The common thread is that everyone who works with an AI system must have sufficient understanding to use it responsibly and with awareness of the risks.

Who falls under it?

The scope is broad. The requirement applies not only to organizations that develop AI, but to every organization that uses AI systems in its operations. An accountancy firm deploying an AI tool for document analysis, a municipality using algorithms for enforcement, a webshop with a recommendation system: all fall under Article 4. Because AI functionality is now embedded in countless common software packages, in practice hardly any organization escapes its reach.

Enforcement from August 2026

The obligation has existed since February 2025, but the European Commission has confirmed that supervision and enforcement of the AI literacy rules only start from 2 August 2026. That gives organizations time to get their approach in order, but it is no reason to wait. The obligation already formally applies, and in the event of incidents or complaints, demonstrable implementation is the difference between compliance and non-compliance.

How do you meet it?

A workable approach starts with an inventory of where AI is used in the organization and which roles come into contact with it. Then you determine, per role group, what level of literacy is appropriate. For most employees a basic understanding suffices: what AI is, what its limits are, what risks it brings, and what the internal policy for responsible use is. For specialist and decision-making roles you go deeper.

It is important that the organization records the measures taken. A training overview, an internal guideline, registration of who followed which instruction: that is the evidence that the organization meets Article 4. We see that organizations linking AI literacy to their broader AI governance, for example within an ISO 42001 program, organize this most efficiently. The literacy requirement then becomes part of the awareness and competence policy the standard requires anyway.

The benefit beyond compliance

AI literacy is more than a checkbox. Organizations whose staff understand what AI can and cannot do make better choices about where they deploy AI, recognize sooner when an outcome is wrong, and fall victim less easily to shadow AI. The obligation under Article 4 enforces something an organization should want even without the law: employees who deal with AI knowledgeably.

Secure Audit helps organizations set up an AI literacy program that matches their own roles and risks and demonstrably meets Article 4. Contact us for more information.