Training employees on AI is no longer a bonus. It is an obligation that is often overlooked, and enforcement will begin in August 2026.
There is one requirement under the AI Act that has been in effect since February 2025; it applies to nearly every company in Europe, yet most organizations are completely unaware of it. It’s called AI literacy and is mandated by Article 4 of the regulation. It is neither a recommendation nor an example of best practice. It is a legal obligation. And although it has not yet been widely enforced, that will soon change.
Companies often think that AI regulation applies only to tech giants in Silicon Valley. The reality is quite different. Article 4 applies to every organization that uses AI systems, regardless of size or industry. And by 2026, that means virtually every company whose employees open a chatbot, use an AI feature in everyday software, or generate content using artificial intelligence.
What Exactly Does Article 4 of the AI Act Say?
The wording of the obligation is brief, but far-reaching. Providers and deployers of AI systems must take measures to ensure a sufficient level of AI literacy among their employees and other individuals who work with AI systems on their behalf. In doing so, they must take into account the technical knowledge, experience, and education of these individuals, as well as the context in which the AI systems are used.
Three key points emerge from this sentence. First, the obligation applies to “deploying entities,” that is, anyone who uses AI in a professional context. Almost every European employer falls into this category the moment an employee opens any AI tool to assist with their work. Second, the obligation applies not only to employees but also to external collaborators, contractors, and other individuals acting on behalf of the company. Third, the regulation does not specify the form or scope of the training. It does not state how many hours it should last, what format it should take, or what course must be completed. Instead, it requires that the level of literacy be appropriate to the role and the risk.
Important Deadline: When the Obligation Takes Effect
Here is a detail that many companies overlook and that has significant practical implications. The obligation itself, under Article 4, has been in effect since February 2, 2025. What changes on August 2, 2026, is that national market surveillance authorities will gain formal powers to enforce this obligation.
In other words, the obligation existed until August 2026, but there was no mechanism to enforce it. From that date onward, any company that cannot demonstrate sufficient AI literacy among employees working with its AI systems will be subject to regulatory action. It is important to note that although many of the AI Act’s obligations were postponed by the so-called Digital Omnibus agreement of May 2026, Article 4 was not postponed. Its enforcement remains scheduled for August 2, 2026.
The fine for violating Article 4 falls within the mid-range of the AI Act’s penalty regime, i.e., up to 7.5 million euros or the applicable percentage of global turnover. In practice, however, experts point out that the enforcement of this specific obligation on its own will likely be less common than its use as an aggravating factor in a broader investigation. This is because if an incident occurs at a company due to an inadequately trained employee, the lack of training becomes evidence against the company.
What Specifically Must a Company Provide
Since the regulation does not prescribe a specific course, companies have considerable flexibility. However, this does not mean that doing nothing is sufficient. Both the European Commission and national authorities have indicated what elements a robust AI literacy program should include.
Employees must understand what they are working with
A general understanding is essential. Employees should know what AI is, how it works in general, which AI systems are in use at the company, and what opportunities and risks are associated with them. The goal isn’t to turn everyone into a machine learning engineer. The goal is for everyone to understand the basics, limitations, and risks of the AI they use in their daily work. The Commission explicitly noted that simply referring employees to the AI system’s user manual is generally not enough.
Role-Based Training
This is where most companies go wrong. A single, generic training module applied equally to all employees is unlikely to meet the requirement of taking into account the technical knowledge and specific roles of individual employees. A compliance manager overseeing an AI credit scoring model, for example, needs different knowledge—they must understand how the model generates its outputs and where its weaknesses lie. And a marketing assistant using a generative tool needs entirely different knowledge; they must focus on verifying outputs, being aware of bias, and following company rules for AI-generated content. A reasonable approach, therefore, involves distinguishing between groups of employees based on how they use AI and the level of risk involved.
Proving that training took place
Regulators will request records in the event of an audit. An organization that cannot provide them faces risk, regardless of how good its program actually was. Defensible documentation therefore includes a description of the program and its scope, records of training completion for individual employees by role and date, proof of verification of acquired competencies, and a record of content updates. It is precisely this ongoing updating that is important, as it demonstrates that the company is taking a proactive approach to its obligations, rather than treating them as a one-time box-checking exercise.
Interconnection with High-Risk Systems and Human Oversight
AI literacy is not an isolated obligation. It is structurally linked to other provisions of the AI Act, particularly the requirement for human oversight of high-risk systems. The regulation requires that individuals entrusted with human oversight possess the necessary competence, training, and authority to perform their duties.
This has a fundamental practical implication for companies. The work done to comply with Article 4—namely, the inventory of AI systems, the assignment of roles, and training records—also serves as the foundation for the more demanding documentation of high-risk systems, which is due eighteen months later. A company that builds a solid AI literacy program today will make it significantly easier to meet the stricter obligations that lie ahead.
Why It’s Also in the Company’s Own Best Interest
It would be a mistake to view AI literacy merely as a burden. Well-trained employees make fewer mistakes, rely less on erroneous outputs, do not enter sensitive data into the wrong tools, and know how to make full use of AI. Furthermore, research shows that where management actively uses AI itself and visibly invests in employee development, positive perceptions of AI among employees increase significantly. Training is thus not just a matter of complying with legal obligations, but also a direct cost-saver and a safeguard against risk.
There is also a credibility aspect. A demonstrable investment in AI literacy becomes one of the hallmarks of mature AI governance, which is valued by both regulators and business partners. A company that can demonstrate it has prepared its employees to work with AI appears more trustworthy than one that leaves it to chance.
Sources
- European Commission, AI Literacy Questions & Answers (enforcement as of August 2, 2026, national authorities): https://digital-strategy.ec.europa.eu/en/faqs/ai-literacy-questions-answers
- ComplyLoft, Article 4 AI Literacy Enforcement Starts August 2, 2026 (deadlines, penalty rate): https://www.complyloft.com/blog/eu-ai-act-article-4-ai-literacy
- Internal, EU AI Act Article 4: Mandatory AI Literacy Training Explained (program elements, documentation): https://iternal.ai/eu-ai-act-literacy
- Crowell & Moring, Employer AI Literacy Obligations under the EU AI Act (differentiated approach, “other persons”): https://www.crowell.com/en/insights/client-alerts/part-2-ai-literacy-employer-ai-literacy-obligations-under-the-eu-ai-act
- Regulation (EU) 2024/1689, Article 4 (full text): https://artificialintelligenceact.eu/article/4/
This article is for informational purposes only and does not constitute legal advice
