EU AI Act and AI literacy what Article 4 really says
Updated October 5, 2026 · 6 min read
Since February 2, 2025, Article 4 of the EU AI Act has required companies that provide or use AI systems in the European Union to take measures to support their staff’s AI literacy. The text was rewritten in July 2026: it no longer speaks of a “sufficient level” and specifies that no particular level has to be guaranteed for each person. It imposes no training format, no duration, and no certificate.
What Article 4 says today
Article 4 of Regulation (EU) 2024/1689 is titled “AI literacy.” In the version in force since July 27, 2026, it says that providers and deployers of AI systems take measures to support the development of AI literacy among their staff and among the other persons who deal with the operation and use of these systems on their behalf.
These measures take into account each person’s technical knowledge, experience, education, and training, the context of use, and the people on whom the AI is used. The text adds that the obligation does not require guaranteeing a specific level of literacy for an individual.
AI literacy is defined in Article 3: the skills, knowledge, and understanding that allow an informed deployment of AI systems.
What changed in July 2026
The first wording, applicable since February 2, 2025, asked companies to “take measures to ensure, to their best extent, a sufficient level of AI literacy.” Regulation (EU) 2026/1744 of July 8, 2026, known as the digital omnibus on AI and published in the Official Journal on July 24, 2026, rewrote the article. The obligation remains, but it now concerns measures to take, no longer a level to reach.
The same text tasks the Commission and the member states with supporting companies, small and midsize businesses in particular. If you read “sufficient level” elsewhere, that is the old wording.
Who is covered
- Any organization that uses an AI system in its business in the European Union. The regulation calls “deployer” anyone who uses an AI system under their own authority, outside a personal, non-professional activity. There is no size threshold: a very small business is covered.
- Providers, who develop an AI system and place it on the market.
- Staff, and beyond: the other people who use AI on the company’s behalf, such as contractors.
- Even for everyday use. Employees who write or translate with ChatGPT? The European Commission answers yes: they must be informed of the risks specific to the tool, such as made-up answers.
What to do, in practice
The text sets no format, no duration, and no curriculum. In its questions and answers updated on July 27, 2026, the European Commission suggests four points:
- Give everyone a general understanding of AI and of what the company uses.
- Identify the company’s role: does it develop AI systems, or does it use other people’s?
- Look at the risks of the systems in use, and at what staff need to know to limit them.
- Adapt the actions to each person’s level, to the job, and to the context.
It also specifies that having people read the instructions for use is often not enough, that no certificate is required, that there is no obligation to measure employees’ level, and that the company may keep an internal record of its training and its other actions. For high-risk AI systems, a separate rule (Article 26) requires that the people assigned to oversee them be trained.
The timeline and enforcement
| Date | What happens |
|---|---|
| August 1, 2024 | The AI Act enters into force. |
| February 2, 2025 | Article 4 becomes applicable. |
| July 27, 2026 | The new wording of Article 4 enters into force. |
| August 2026 | The supervision and enforcement rules apply (from August 3, 2026, according to the Commission). |
Enforcement falls to the national market surveillance authorities, not to the Commission’s AI Office. Penalties are set by each member state’s law; the Commission says they must be proportionate. So check which authority your country has designated. In France, for example, the government presented in September 2025 a plan that splits this role among several authorities, coordinated by the DGCCRF (the French consumer protection and market surveillance agency), subject to a vote in Parliament: check where that text stands.
This page explains the text. It does not replace legal advice: for your situation, talk to a lawyer.
What Nova brings, and what it does not
Nova is subscription software that trains each person on AI according to their job and their level: for each use case, the tool, the prompt, the limits, and the precautions about data. It is a concrete measure, to note in your internal record along with your policy and the list of approved tools. Use cases are sorted on AI training by job.
Nova alone is not enough to make you compliant: it is up to the company to choose its measures and to keep track of them. It does not issue individual certificates, and the company never sees one person’s activity in it. Nova is software, not an accredited training provider: it issues no diploma or certification. From €19 per month: see pricing or try the interactive demo.
Frequently asked questions
Is AI training mandatory for companies in the EU?
Yes, in a broad sense: Article 4 requires companies that provide or use AI systems to take measures to support their staff’s AI literacy. It imposes no course and no number of hours: the choice of means is free.
Since when has the obligation applied?
Since February 2, 2025. The current wording of Article 4 has been in force since July 27, 2026, and the supervision and enforcement rules have applied since August 2026.
Do you need a certificate?
No. The European Commission says no certificate is needed. The company may keep an internal record of its actions.
Are small businesses covered?
Yes: Article 4 sets no size threshold. Since July 2026, the text has asked the Commission and the member states to support small and midsize businesses in particular.
What does a company risk if it does nothing?
Penalties are a matter for national law and the market surveillance authorities. The European Commission specifies that they must be proportionate. To assess your risk, consult a lawyer.
Sources
- Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence (AI Act), EUR-Lex, European Union
- Regulation (EU) 2026/1744 of July 8, 2026 (digital omnibus on AI): new wording of Article 4, EUR-Lex, Official Journal of the European Union, July 24, 2026
- Regulation (EU) 2026/1744: document information and dates of entry into force, EUR-Lex, European Union
- AI literacy: questions and answers (updated July 27, 2026), European Commission
- Article 4: AI literacy (original wording), European Commission, AI Act Service Desk
- Article 3: definitions (deployer, provider, AI literacy), European Commission, AI Act Service Desk
- AI Act: regulatory framework and application timeline, European Commission
- The competent authorities for implementing the EU AI Act in France (September 9, 2025, in French), Direction générale des entreprises, French Ministry of the Economy
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