What the law asks
What the law actually asks for.
The page to send your compliance lead or your board. Article 4 as it stands after July 2026, what the Commission says a programme should cover, and what is not required.
Article 4 after the Omnibus.
The Digital Omnibus rewrote Article 4 in July 2026. The duty is now to take measures that support the development of AI literacy, and the text is explicit that you are not required to guarantee any particular level for any individual. What gets assessed is what your organisation did.
Two things follow. The European Commission states plainly that no certificate is required, and that organisations can keep an internal record of training and guidance. There is also no obligation to measure your employees' AI knowledge.
We build to the Commission's own published guidance. Its Q&A sets out four steps any Article 4 programme should cover. Here is how our workshops map to them.
| Step | The Commission asks | Where we cover it |
|---|---|---|
| a | The Commission asksWhat is AI, how does it work, what AI is used in our organisation, and what are its opportunities and dangers? | Where we cover itOpening module: what AI is and how your tools use it |
| b | The Commission asksIs our organisation developing AI systems, or using systems built by others? | Where we cover itRole and tool inventory |
| c | The Commission asksWhat do staff need to know about these systems, what risks, and what mitigations? | Where we cover itRisk mapping and role-calibrated depth |
| d | The Commission asksBuild the literacy actions on that analysis, accounting for staff knowledge and the context of use | Where we cover itPolicy workshop and your written record |
Who it applies to.
Article 4 binds every provider and deployer of AI systems, whatever the industry. It has applied since 2 February 2025, and national market surveillance authorities have supervised and enforced it since 2 August 2026. In Ireland that means your existing sectoral regulators, coordinated by the AI Office of Ireland.
- 01
Everyday AI tools
Staff using ChatGPT or similar to write copy, summarise documents or translate. The Commission's own guidance confirms these organisations are in scope and must inform staff about specific risks such as hallucination.
- 02
AI inside software you already bought
Recruitment screening, HR platforms, finance tools and customer service software increasingly ship AI features by default. You are a deployer whether or not you chose the feature.
- 03
Customer-facing AI
Chatbots, deepfakes and certain AI-generated content carry separate transparency duties under Article 50, in force since 2 August 2026 and not deferred by the Omnibus.
- 04
Contractors and agencies
The duty covers people who deal with AI on your behalf but are not on your payroll. Contractors, service providers and agencies should be covered by the same measures as your employees.
57.7%
of large Irish enterprises, with 250 or more staff, used AI in 2025. Across all enterprises with ten or more staff the figure was 20.2%. CSO, Information Society Statistics: Enterprises 2025
What about high-risk AI systems?
Article 4 applies now. The separate Article 26 duty on deployers of high-risk systems, such as AI that scores creditworthiness or screens job candidates, is to assign human oversight to people with the competence, training and authority to do it, and the Commission is explicit that relying on a system's instructions for use is not sufficient.
The Digital Omnibus moved most of those obligations to 2 December 2027, and a system already in service before that date is only brought in once its design changes significantly. Training for oversight roles is a separate, deeper engagement that we scope on a call.
A generic course cannot do step (d). Calibration to your tools, your roles and your context is the judgement Article 4 actually asks for, and the record of that judgement is what you keep.
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.
Related insights.
Article 4
What changed in Article 4 of the EU AI Act in July 2026?
Regulation (EU) 2026/1744, the Digital Omnibus on AI, rewrote Article 4 on 24 July 2026. The duty is now to take measures that support AI literacy, no specific level is mandated, and what gets assessed is what your organisation did.
Article 4
What is AI literacy under the EU AI Act?
Article 3(56) defines AI literacy as the skills, knowledge and understanding that let people make an informed deployment of AI systems and understand their opportunities, risks and possible harm. It is a working capability tied to the tools in use, not a qualification.
Article 4
Do we need to test our employees' AI knowledge under Article 4?
No. Article 4 does not require you to test employees or have them pass an assessment. The duty is to take measures that support AI literacy, and the record of those measures is what matters.
Sources
Checked against the sources below on 1 October 2026.