The AI training obligation: what applies now — and how to meet it
Article 4 of the EU AI Act requires AI literacy from everyone who works with AI on your behalf. Here is what that means in practice, what is not required — and how to see where your company stands in three minutes.
12 questions · 3 minutes · instant result
Timeline · Article 4
2 February 2025
In force. The obligation applies to providers and deployers.
7 May 2026
Digital Omnibus: much is postponed — Article 4 is not.
2 August 2026
Enforcement by market surveillance authorities.
What the obligation requires — and what it doesn't
Article 4 of the EU AI Act requires you to ensure a sufficient level of AI literacy among the people who work with AI on your behalf. The measure is their prior knowledge, their role, and the context of use — not any particular course format. Much of what the market is selling right now is simply not required.
This applies
- Since 2 February 2025 — to providers and deployers of AI. Industry and company size do not matter.
- Using ChatGPT, Microsoft Copilot, or an AI recruiting tool in your business is already enough to trigger the obligation.
- Measures have to fit roles and risks — and hold up if you are audited.
- From 2 August 2026, market surveillance authorities can act on breaches.
What's not required
- No certificate: the AI Act has no certification requirement. (EU AI Office FAQ)
- No mandatory knowledge test or exam for employees.
- No dedicated AI officer role.
- No prescribed format: internal or external, online or on site — anything that demonstrably works is fine.
The Digital Omnibus (agreement of 7 May 2026) postpones much of the AI Act, such as the high-risk obligations of Annex III to December 2027. The Article 4 literacy obligation is not among them: it continues unchanged.
Self-check
The self-check: could you prove compliance today?
12 yes/no questions — in the same logic an authority would use: which AI runs in your company, which rules apply, who has been trained, and is it all documented?
1 · Inventory
Do you have a current inventory of all AI systems and tools in use — including ChatGPT, Copilot & co.?
Do you know which employees use which AI tools in which processes?
Is it clear whether you are a deployer or a provider under the regulation for each system?
2 · Rules
Is there a written AI usage policy for your employees?
Is it defined which data may be entered into AI tools — and which may not?
Is there a defined process for approving new AI tools?
3 · Literacy
Have your employees been trained on how AI works, its limits and risks — bias, hallucinations, data protection?
Is training differentiated by role — all employees, leadership, specialist teams?
Have managers been trained on responsibility and liability when using AI?
4 · Documentation
Do documented certificates of attendance exist for all training measures?
Could you present your measures to an authority in writing within a week?
Is there a process that updates training and policy when tools or risks change?
0 of 12 answered
Who the obligation covers in your company
Everyone who works with AI — but not everyone equally. The regulation requires literacy that fits the role and the risk.
Executive leadership
Carries the obligation and owns the implementation. Needs an overview of the risks and responsibilities.
Sales
Customer data in proposals and emails: this is where confidentiality is won or lost day to day.
HR
The regulation classifies recruiting AI as high-risk — special care applies here.
Marketing
AI-generated content needs an eye on copyright and labelling.
Customer service
Where AI talks to customers, the transparency duties of Article 50 apply.
IT and operations
Introduce AI tools — and must be able to document operation and approvals.
Legal basis: Annex III lists recruiting AI as high-risk, Article 50 governs transparency and labelling obligations.
The next step
How to meet the obligation: training that brings the documentation with it
Our AI literacy training is tailored to your roles and your AI systems, and comes with the documentation for your compliance file: certificates of attendance, the content delivered, and the supporting rationale.
- Tailored to roles, prior knowledge and context of use
- Audit-ready documentation for the regulator included
- Delivered by people who build AI themselves
30 min · no obligation · directly with a founder
Who is behind this
Not a course catalogue — a team that builds AI in regulated industries itself.
Frequently asked questions about the obligation
The legal situation in brief — including what is often misunderstood.
Clarity in one conversation
30 minutes with a founder: what the obligation means for your company, where you stand, and the shortest path to a defensible record.
30 min · no obligation · directly with a founder