AI Literacy Training Under Article 4: What Your Business Must Do Now

The Obligation That Caught Everyone Off Guard

Of all the EU AI Act deadlines, Article 4 was the first to bite — and most businesses missed it entirely. On February 2, 2025, the AI literacy requirement took effect. Not in 2026, not in 2027. It is already enforceable law.

Article 4 states that providers and deployers of AI systems shall take measures to ensure, to the best extent possible, a sufficient level of AI literacy among their staff and other persons dealing with the operation and use of AI systems on their behalf.

This is not a future aspiration. If your employees use any AI tool — from ChatGPT to an AI-powered CRM — and you have not taken steps to ensure they understand what they are using, your organization is non-compliant today.

What Exactly Does Article 4 Require?

Article 4 is deliberately broad, but its core elements are clear.

The Legal Text

The full provision reads: "Providers and deployers of AI systems shall take measures to ensure, to their best extent possible, a sufficient level 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."

There are three key phrases worth unpacking.

"To their best extent possible"

This is a proportionality requirement. The EU does not expect a five-person accounting firm to run the same training program as Google. What is expected is a genuine, documented effort that matches your organization's size, resources, and AI usage. A reasonable effort is required — not a perfect one.

"Sufficient level of AI literacy"

Sufficiency is measured against the context. A marketing manager using AI to draft social media posts needs different literacy than an HR director using AI to screen CVs. The law does not define a single standard. Instead, it requires that each person's understanding is adequate for how they interact with AI.

"Taking into account their technical knowledge, experience, education and training"

Training must be tailored. A software developer will need different content than a receptionist. The regulation explicitly recognizes that one-size-fits-all training does not satisfy the requirement.

Who Needs AI Literacy Training?

The short answer: everyone who interacts with AI systems in your organization. Article 4 applies to two groups.

Providers

If your organization develops or supplies AI systems, your entire development and deployment team needs literacy training. This includes engineers, product managers, quality assurance staff, and anyone involved in the AI system lifecycle.

Deployers

If your organization uses AI systems — which is almost every business in 2026 — then everyone who interacts with those systems needs training. This includes:

• Executives and directors who make decisions about AI adoption and strategy
• Managers who oversee teams using AI tools
• Employees who use AI tools in their daily work (ChatGPT, Copilot, AI analytics, etc.)
• Customer-facing staff who interact with AI chatbots or AI-assisted processes
• HR professionals using AI recruitment or performance tools
• Finance teams using AI for forecasting, credit decisions, or fraud detection
• IT staff who manage and maintain AI systems
• Contractors and temporary workers who use your AI systems on your behalf

The phrase "other persons dealing with the operation and use of AI systems on their behalf" is important. It extends beyond full-time employees to anyone acting for your organization.

What Must AI Literacy Training Cover?

The EU AI Act does not prescribe a specific curriculum, but the European Commission and national authorities have provided guidance on what constitutes sufficient AI literacy. Based on the regulation's requirements and emerging best practices, your training should cover these areas.

Foundational AI Knowledge

Every person in your organization should understand:

• What AI is and how it works — at a conceptual level, not a technical one. Employees should understand that AI systems learn from data and make predictions or decisions based on patterns.
• Types of AI systems — the difference between a simple recommendation engine and a system that makes consequential decisions about people.
• Capabilities and limitations — what AI can and cannot do reliably. This is critical for preventing over-reliance.

The EU AI Act Framework

Staff should have a working understanding of:

• The risk-based approach — the four risk tiers (unacceptable, high, limited, minimal) and why they matter.
• Your organization's obligations — what the law requires of your business specifically, based on the AI systems you use.
• Prohibited practices — what AI uses are banned outright, so employees do not inadvertently deploy a prohibited system.

Role-Specific Competencies

Beyond the baseline, different roles need tailored training.

For decision-makers: Understanding the business implications of AI classification, the cost of non-compliance, and how to evaluate AI vendor claims about compliance.

For AI tool users: Knowing how to use specific tools responsibly, when to rely on AI outputs versus applying human judgment, and how to identify potentially biased or incorrect AI outputs.

For technical staff: Understanding data quality requirements, monitoring obligations, documentation standards, and how to implement human oversight mechanisms.

For HR professionals: Special focus on high-risk AI in employment decisions, bias detection, transparency requirements when AI influences hiring or performance evaluations.

Practical AI Ethics

• Bias awareness — understanding that AI systems can reflect and amplify biases in training data
• Data privacy — how AI intersects with GDPR obligations, especially when AI processes personal data
• Transparency — when and how to disclose AI usage to customers, employees, and other stakeholders
• Human oversight — understanding when and how to override AI decisions

How to Build a Compliant Training Program

Here is a practical framework for SMBs that need to get compliant quickly.

Step 1: Map Your AI Landscape

Before you can train people, you need to know what AI your organization uses. Conduct an AI inventory that covers:

• All AI tools currently in use (including free tools employees may have adopted on their own)
• Who uses each tool and for what purpose
• What decisions each tool influences
• Whether any tools fall into high-risk categories

This inventory directly feeds your training plan because it tells you who needs to know what.

Step 2: Segment Your Workforce

Divide your staff into training groups based on their AI interaction level:

• Group A: Heavy AI users — People who use AI tools daily or make decisions based on AI outputs. They need the deepest training.
• Group B: Occasional AI users — People who interact with AI tools periodically. They need solid foundational training plus role-specific guidance.
• Group C: Indirect users — People who are affected by AI decisions (e.g., their performance is tracked by AI) but do not operate the systems themselves. They need awareness training.
• Group D: Leadership — Executives who set AI strategy. They need governance-focused training.

Step 3: Deliver Training

The format matters less than the substance and documentation. Effective approaches include:

• Online modules — Self-paced training that employees can complete around their schedules. Track completion rates.
• Workshop sessions — Interactive sessions where staff can ask questions about specific tools they use.
• Vendor-led briefings — Have your AI tool vendors explain their systems' capabilities and limitations.
• Refresher updates — AI literacy is not a one-time event. Schedule quarterly or biannual updates as tools and regulations evolve.

Step 4: Document Everything

Documentation is what separates good-faith compliance from wishful thinking. Record:

• Training content — what was taught, at what level
• Attendance records — who completed training and when
• Assessment results — if you test comprehension, keep the results
• Training materials — store all materials used
• Update schedule — your plan for keeping training current

If a regulator asks whether you have ensured AI literacy, you need to produce evidence — not just say "yes, we talked about it."

Step 5: Monitor and Update

AI tools change rapidly. New tools get adopted, existing tools add AI features, and regulations continue to evolve. Your training program must be a living process:

• Review and update training content at least twice per year
• Train new employees during onboarding
• Retrain when significant new AI tools are adopted
• Track which employees have current versus outdated training

Common Mistakes to Avoid

Treating It as a Checkbox Exercise

A 10-minute generic video about "what is AI" does not meet the proportionality requirement if your employees are making consequential decisions with AI tools. The training must be genuinely sufficient for the context.

Ignoring Shadow AI

Employees often adopt AI tools without IT approval — using ChatGPT for drafting emails, AI image generators for presentations, or AI coding assistants without formal authorization. Your training program needs to address these tools too, and your AI inventory must account for them.

Training Once and Forgetting

Article 4 requires ongoing literacy, not a one-time event. The AI landscape changes fast. A training session from January 2025 may already be outdated if your organization has adopted new tools since then.

Leaving Out Leadership

Board members and executives are not exempt. If they make decisions about AI strategy and adoption, they need appropriate literacy. In fact, leadership buy-in is what turns a compliance exercise into a genuine competence-building effort.

Not Tailoring to Roles

Generic training that treats all employees the same fails the proportionality test. The regulation explicitly requires you to consider each person's technical knowledge, role, and the context in which they use AI.

The Business Case Beyond Compliance

AI literacy training is not just about avoiding fines. Organizations with AI-literate workforces consistently see:

• Better AI adoption outcomes — Staff who understand AI tools use them more effectively and avoid common pitfalls.
• Reduced risk — Literate employees are less likely to use AI inappropriately, feed sensitive data into public AI tools, or over-rely on AI outputs.
• Stronger vendor relationships — When your team understands AI, you can hold vendors accountable for their claims and negotiate better terms.
• Competitive advantage — AI-literate teams innovate faster and more responsibly than competitors still figuring out the basics.

Enforcement and Penalties

Article 4 falls under the general enforcement provisions of the EU AI Act. While it does not carry the highest penalty tier (which is reserved for prohibited practices), non-compliance with deployer obligations can result in fines of up to EUR 15 million or 3% of global annual turnover, whichever is lower for SMEs.

More practically, failure to demonstrate AI literacy is likely to be an aggravating factor if your organization faces enforcement action for other AI Act violations. If an employee misuses a high-risk AI system and your organization cannot show that adequate training was provided, the regulatory consequences will be more severe.

National authorities across EU member states are currently building their enforcement frameworks. Early enforcement actions are expected to focus on clearly documented obligations — and Article 4's requirement to "take measures" with documented evidence is exactly the kind of obligation that is straightforward to enforce.

How AktAI Helps With AI Literacy Compliance

AktAI makes Article 4 compliance practical for SMBs:

• AI system inventory — Automatically catalogue every AI tool in your organization, including who uses it and for what purpose.
• Training records — Track which employees have completed training, when, and at what level. Generate audit-ready reports on demand.
• Gap analysis — Identify which employees still need training and what topics are not yet covered.
• Risk-aware training mapping — Match training depth to the risk level of the AI systems each employee uses, ensuring proportionate compliance.
• Compliance documentation — Generate the documentation you need to prove your AI literacy measures to regulators.

The Article 4 deadline has passed. Every day without a documented AI literacy program increases your exposure. The good news is that getting compliant does not require months of work — with the right tools, most SMBs can establish a compliant training framework in days, not months.

Check where your organization stands today. Take our free compliance assessment to see your AI literacy gaps and get a prioritized action plan.