Do directors and board members need AI literacy training too?
If directors use AI tools for board work, such as summarising board papers, Article 4 covers them like any other user. Beyond that, the board oversees how the organisation uses AI, and directors need enough understanding to ask good questions about it. They do not need technical depth.
What does Article 4 say that touches directors?
Article 4 covers "staff and other persons dealing with the operation and use of AI systems" on the organisation's behalf. A director who pastes a board pack into an AI tool to get a summary is using an AI system for the organisation. That use is inside the article, and the director needs to know what the tool does with the document and where it gets things wrong.
What is still open?
Nobody has said whether Article 4 reaches a non-executive director who never touches an AI tool. The Commission's Q&A does not address boards at all. We would not tell a board it is legally required to sit a course on that basis, and we would be wary of anyone who does.
How ready are Irish boards?
The Institute of Directors Ireland polled 378 directors and senior business leaders, all IoD members, between 24 February and 6 March 2026. Half called themselves intermediate users of digital and AI tools and 35 percent beginners. 48 percent said their board had discussed AI governance at a formal meeting in the past year. 76 percent said AI-generated summaries of board papers should only supplement their own reading.
What we recommend
This is our view. A board needs a shorter and different session from the staff. It should cover which AI tools the organisation uses and for what, what could go wrong with each, what the executive has done about it, and what the record of that looks like. A board that has seen the inventory and the record can ask better questions than one that has sat through a general talk on AI.
Directors who use AI for their own board work need the same baseline as any user: what must never be uploaded, and why a fluent summary can be wrong.
What to do before the next board meeting
- Ask the executive for the AI tool inventory and the training record. If neither exists, that is the first agenda item.
- Ask each director whether they use AI tools on board papers, and which ones.
- Put AI governance on the agenda once, formally, and minute it.
- Agree who on the executive reports back and how often.
When a board does not need a trainer
If the executive can present a clear inventory and a dated record, and nobody on the board uses AI tools on board material, a well-prepared agenda item may be all you need. A briefing is worth the board's time when it is being asked to approve a tool that screens, scores or ranks people, or when directors are already using AI on confidential papers. Our trainers are named on the trainers section.
Sources
Checked on 30 September 2026.
- Regulation (EU) 2024/1689, the AI Act, Article 4 as amended by Regulation (EU) 2026/1744.
- Institute of Directors Ireland, AI and Business Confidence Snap Poll, Q1 2026.
- European Commission, AI literacy: questions and answers.
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.
