AI governance

What does the EU AI Act require for AI literacy?

Direct answer

Article 4 of the EU AI Act requires providers and deployers of AI systems to take measures to support the AI literacy of their staff and of others who operate or use AI systems on their behalf, taking into account their knowledge, experience, training and the context of use.

It has applied since 2 February 2025, and Regulation (EU) 2026/1744 reworded it as a duty of means: it does not require a guaranteed level of literacy for any individual.

Who Article 4 covers

Every provider and every deployer of an AI system, whatever the risk class. A company whose staff use a general-purpose chatbot, a writing assistant or an AI feature in a business tool is a deployer of that system. The duty covers its staff and other persons dealing with the operation and use of AI systems on its behalf, such as contractors.

What changed with the Digital Omnibus

The original text asked providers and deployers to ensure, to their best extent, a sufficient level of AI literacy. Regulation (EU) 2026/1744, in force since 27 July 2026, replaced Article 4: providers and deployers now take measures to support the development of AI literacy, without having to guarantee any specific level for any individual, and the Commission and the member states support those efforts. The obligation itself stays, and national authorities supervise it.

What measures make sense

  • Know your AI use: keep a register of the AI systems your teams build, buy or use, and who uses them.
  • Match the training to the role: general awareness for every user, deeper training for people who configure systems, oversee them or decide on their output.
  • Set rules: an acceptable-use policy for AI tools, read and acknowledged by staff.
  • Keep records: who was trained or acknowledged which version, and when.
  • Review: update the measures when you add systems or the use changes.

For high-risk systems, Article 26(2) separately requires deployers to assign human oversight to people with the necessary competence, training and authority.

Showing AI literacy measures in Acuna GRC

In AI Governance in Acuna GRC, the AI system register shows which systems you use and who they affect, and each overseer assignment records a competence basis. In the Staff Portal, you publish your AI use policy and staff read and acknowledge it, with campaigns and reminders, and each acknowledgement is kept with the version read. See AI Governance in Acuna GRC.

How Acuna GRC handles it

In Acuna GRC you keep the training and acknowledgement records that show the measures.

Sources

  1. Regulation (EU) 2024/1689 (EU AI Act), Articles 2, 3(56), 4 and 26
  2. Regulation (EU) 2026/1744 (Digital Omnibus on AI)

This page explains the rules in general terms and is not legal advice.

Frequently asked

Do we need an AI literacy certificate for staff?

No. Article 4 does not require a certificate or a set course. Measures that fit your AI use and records that show them are what matter.

Does Article 4 apply to Swiss companies?

It applies to providers and deployers within the scope of the EU AI Act, which includes companies outside the EU that place AI systems on the EU market or whose AI output is used in the EU.

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