This guide places Article 4 of Regulation (EU) 2024/1689 for leaders. It is not legal advice. Check the wording in EUR-Lex. The Commission describes the current text in the questions and answers on AI literacy.
Who the duty covers
Article 4 is addressed to providers and deployers of AI systems. It covers their staff and other people who deal with the operation or use of the systems on their behalf. The Commission also gives contractors, service providers or customers as examples, when those people operate the systems for the provider or deployer.
The first rules, including AI literacy, have applied since 2 February 2025. The Commission said so on that day.
What is required and what is not
Providers and deployers must take measures that support the AI literacy of these people. That takes account of their technical knowledge, experience, education and the context in which the systems are used.
The Digital Omnibus, Regulation (EU) 2026/1744, amended Article 4. As the Commission describes it, the duty remains. A specific or “sufficient” level of literacy for any one person is not required. There is also no duty to measure each person’s knowledge. For high-risk systems, training for human oversight under Article 14 remains in place alongside it.
How to build the measures
Start with the list of systems your company provides or uses. For each system, note who operates it, which data it sees and which decision a person still makes. The exercise comes from that, not from a general tool catalogue.
- Record each person’s role and existing experience.
- Describe one recurring task and the result you want.
- Define how you recognise a usable result and when you stop.
- After the exercise, note what you will repeat. That is your record of the measure, not a certificate.
A Copilot licence or a single prompt workshop does not replace this mapping. What training on one specific tool can look like is in the guide on Copilot training for companies.
Germany, Austria and Switzerland
Germany and Austria are EU member states. Whether Article 4 applies to you depends on whether you are a provider or deployer within the meaning of the Regulation. Switzerland is not an EU member. A seat in Switzerland alone does not create the duty. If you make systems available in the Union, or the output is used there, the Regulation’s scope rules apply. You check that in the text, not in this guide.
How to build a programme for a company is described in AI training for companies.