Article 4 after the Digital Omnibus: what does a credit union need to do?
List the AI tools your credit union runs, brief the staff and volunteers who use them on what each tool does and where it fails, and write down what you did. Since July 2026 Article 4 asks for measures, and a credit union does not have to prove what any individual knows. For most credit unions that is a few hours of preparation, one session and a short written record.
Does Article 4 apply to a credit union at all?
Yes. Article 4 applies to every provider and deployer of AI systems, and a deployer is any organisation that uses an AI system under its own authority for work. The AI Act has no exemption for credit unions and no size threshold. If a member services officer drafts a reply with Microsoft Copilot, or a loan officer reads a score produced by the lending platform, the credit union is a deployer.
The duty has applied since 2 February 2025. Regulation (EU) 2026/1744, the Digital Omnibus on AI, rewrote it from 27 July 2026. The current text requires you to take measures to support the development of AI literacy among your staff and the other people who use AI on your behalf, and it states that you are not required to guarantee any specific level of AI literacy of any individual.
The checklist
- Write the inventory. One page. Each AI system, what it is used for, and which roles use it. Include the general-purpose assistants (ChatGPT, Copilot), the AI features inside software you already own (lending, transaction monitoring, the phone system, the website chatbot), and anything a volunteer uses on board papers.
- Ask your software providers two questions. Does this feature use AI, and does it score, rank or flag members? Keep the replies with the inventory.
- Decide who needs what. Everyone who uses a tool needs the baseline: what it does, where it goes wrong, and what must never be typed into it. Loan officers and the credit committee need more on the scoring feature. The board needs to see the inventory and know who answers for it.
- Deliver it live. A session where people can ask about their own tools does more than a video. Include volunteers and any contractor who works on your systems.
- Write the record. What was covered, who attended and when, and why that depth suited those roles. Date it and have someone sign it.
- Set a review date. Six to twelve months out, or sooner if a new tool arrives or a merger brings in new staff and systems.
What you can leave out
The European Commission's Q&A on AI literacy says no certificate is required and that organisations can keep an internal record of training and guidance. It also says Article 4 carries no obligation to measure what employees know. So a credit union does not need to test anyone, buy a certificate for each staff member, or appoint an AI officer.
What the Central Bank has said
The Central Bank's Regulatory and Supervisory Outlook 2026 has a section on AI. It asks firms that deploy AI to make sure the use fits the business problem, to set clear accountability with human oversight and explainability, to keep governance proportionate to the scale and sensitivity of the use, and to have processes for meeting their AI Act obligations. We have not found Central Bank guidance written for credit unions on Article 4.
Article 4 carries no fine of its own, under the AI Act or under Ireland's Regulation of Artificial Intelligence Act 2026. Fitness and probity does apply to credit unions, and a dated record is what a board points to when someone asks what it did.
Where to start
If nobody has written the inventory, start there. It takes an afternoon and it tells you how much of the rest you need. Our page on AI Act training for credit unions sets out who should be covered and what the record looks like.
Sources
Checked on 1 October 2026.
- Regulation (EU) 2024/1689, the AI Act, Article 4 as amended by Regulation (EU) 2026/1744.
- European Commission, AI literacy: questions and answers.
- Central Bank of Ireland, Regulatory and Supervisory Outlook 2026, Spotlight 1.
- Regulation of Artificial Intelligence Act 2026 (No. 31 of 2026).
This is general information about the EU AI Act, not legal advice. Enforcement is proportionate and case by case, and your sectoral regulator may issue guidance that applies to you.
