Sector
AI literacy training for marketing and agencies.
AI-generated copy, imagery and video are standard agency output. The people producing it fall under Article 4, which asks you to take measures that help them understand the tools behind it. Article 50 adds disclosure duties for some of what they make.
Where AI is already in the work
- Copy, campaign and social content drafted with generative tools
- AI-generated and AI-edited imagery, voice and video
- Audience segmentation and ad-targeting features in marketing platforms
- Chatbots and automated replies on client channels
- Transcription and summarisation of client calls
What the AI Act asks of you
Article 4 applies to every organisation whose staff use an AI system at work, and it has applied since 2 February 2025. Supervision and enforcement by national authorities started on 2 August 2026. The duty is to take measures that support the development of AI literacy among your staff and the people using AI on your behalf, calibrated to the tools in use, the people using them and the context. The Commission's Q&A is explicit that no certificate is required and that organisations can keep an internal record of training and guidance.
Article 50 requires deployers of AI that generates or manipulates image, audio or video content constituting a deep fake to disclose that the content has been artificially generated or manipulated. It also requires disclosure of AI-generated text published to inform the public on matters of public interest, unless the text has undergone human review or editorial control and a person holds editorial responsibility. Those transparency duties applied from 2 August 2026 and were not deferred by the Digital Omnibus.
Agencies sit on both sides of Article 4. Your own staff are covered as employees. When you use AI on a client's behalf, the Commission's Q&A says people working for a service provider or contractor need the appropriate AI skills for the task, the same as employees, so clients can reasonably ask what measures you have taken and what record you hold.
Which workshop fits
Agencies typically put everyone through the half day, and use the full day where the people who set up generative or targeting tools need depth and a policy that answers disclosure, client confidentiality and what may go into a tool.
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.
Questions from this sector.
Do we have to label AI-generated images?
Where the content is a deep fake, meaning it resembles existing people, objects, places, entities or events and would falsely appear to a person to be authentic, Article 50 requires the deployer to disclose that it has been artificially generated or manipulated. Ordinary generated illustration that does not pass as real is not caught by that duty, and we work through the line with your own examples.
Our clients are asking about AI literacy. What should we show them?
The record the Commission describes: what training or guidance your staff received, who attended, when, and why that depth suited those roles. Every tier of our workshops leaves you with that record written.
Does Article 4 apply to freelancers we use?
Yes. Article 4 covers the people dealing with AI on your behalf, and the Commission's Q&A names contractors and service providers. You can include them in a session, share your policy, or confirm in the contract that they hold their own record.
Related insights.
Scope
Does Article 4 cover contractors and agencies working for us?
Yes. Article 4 covers people who deal with AI on your behalf whether or not they are on your payroll, so your measures should reach contractors, service providers and agencies too, in proportion to the systems they touch.
Scope
Does the EU AI Act apply to us if staff only use ChatGPT?
Yes. The European Commission's Q&A says a company whose employees use ChatGPT for tasks like writing or translating must comply with Article 4, and should inform staff about specific risks such as hallucination.