Is AI training compulsory? What Article 4 of the EU AI Act requires

Many business owners have heard that AI training is now compulsory and want to know what that means for their team. The rule is real, and it is set out in a single article of the EU AI Act, Article 4, which deals with AI literacy. The article is short and its wording was changed in 2026, so the current text should be read closely.

What Article 4 says

Article 4 of Regulation (EU) 2024/1689 was replaced in 2026 by Regulation (EU) 2026/1744. Paragraph 1 now reads:

‘Providers and deployers of AI systems shall take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be used. This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual.’

The obligation is to take measures. It covers the company's own staff and also other people who operate or use AI systems on the company's behalf. The measures should take into account the technical knowledge, experience, education and training those people already have, the context in which they will use AI, and the people on whom it is used, for instance customers who receive a reply drafted with the help of an AI tool.

For an owner, the part that matters most is the second sentence of paragraph 1, under which the obligation does not require anyone to guarantee a specific level of AI literacy in any individual. The original 2024 version asked for measures to ensure, ‘to their best extent, a sufficient level of AI literacy’. If you read material written before the amendment, that is the wording you will find.

The obligation has applied since 2 February 2025.

Does it apply to your company?

Article 4 applies to two kinds of organisation: providers, which, broadly, develop AI systems and place them on the market, and deployers. For a company that uses AI tools without building them, the second category is the one that matters.

Article 3 of the regulation defines a deployer as ‘a natural or legal person, public authority, agency or other body using an AI system under its authority except where the AI system is used in the course of a personal non-professional activity’.

The exception covers personal use, such as someone using an AI assistant at home for private matters. When a company's team uses AI systems to answer customers or summarise work documents, the use is professional and the exception does not apply.

Paragraph 1 makes no distinction by company size. A company of 12 people and one of 200 have the same obligation, and the text itself asks for each company's context to be taken into account, which, on our reading, allows the measures to be fitted to the case.

Hours, certificates and format

Article 4 does not mention training hours, certificates, exams or a required format, and it does not say the measure has to be a course. The word ‘training’ appears in paragraph 1 in a list of things to take into account about the people concerned, alongside technical knowledge, experience and education.

On our reading, this leaves the choice of measure to the company. A practical session with the team or an internal guide setting out how the tools may be used are both possible measures, and the text does not prefer either.

This page deals only with the AI Act and leaves aside other rules on staff training, such as those in Portuguese employment law.

What support does the text provide for small companies?

Paragraph 2 of Article 4 says the European Commission and the Member States shall support and facilitate the efforts of providers and deployers in meeting this obligation, ‘in particular SMEs’. For that purpose, it says the Commission shall publish practical examples of how to comply, on a single information platform provided for in the regulation itself.

A small company can use those examples as a reference when it decides which measure to adopt.

A sensible measure for a company of 10 to 250 people

For companies of this size we recommend the steps below, although Article 4 does not impose any of them in particular.

1. Find out which AI tools are in use, and by whom. A simple list is enough: the tool, what it is used for, who uses it and with what data. Include the free accounts people have opened on their own initiative.
2. Train the team on its own tasks. The text asks for the context of use to be taken into account, and a session built around the emails and documents the team handles every day meets that criterion directly. It helps to cover what the tool does well, where it can go wrong, which data must not go into it, and who checks the output before it reaches a customer.
3. Keep a written record: the list of who took part, with the date, and a summary of what was covered. Although Article 4 does not require this record, we recommend it because it helps the company show what it did if a customer or partner asks.
4. Come back to it when something changes, for example when a new tool arrives or new people join the team.

Our Workshop: AI in daily work is one such measure. In a half-day session with up to 15 people we work on the team's own tasks, and at the end the company has a written record of who took part and what was covered.

Where to start

If you do not yet know which tools your team uses, start with that list, because the other decisions depend on it. Our EU AI Act checklist includes AI literacy among the points to check and helps you see which other parts of the regulation may concern your company.

This article is general information about the EU AI Act and is not legal advice.