How the obligation has moved.
| Date | What happened |
|---|---|
| 2 February 2025 | Article 4 starts to apply: providers and deployers must ensure, to their best extent, a sufficient level of AI literacy. |
| 24 July 2026 | Regulation (EU) 2026/1744 (Digital Omnibus on AI) published in the Official Journal; in force 27 July 2026. |
| After the Omnibus | Wording reported as: take measures to support AI literacy; no guaranteed level for any individual. |
| 2 August 2026 | National market-surveillance authorities supervise the AI Act's rules, as reported. Article 4 has no fine tier of its own in the Act. |
Dates and the amended wording are taken from the AI Act on EUR-Lex and a secondary summary of Regulation 2026/1744; check the consolidated text before relying on them.
What 'measures' can look like.
List every AI tool in use, who uses it and for what: chat assistants, meeting notes, an AI receptionist, AI in your CRM.
One page: approved tools, what data may never be pasted in, when output must be checked by a person, who to ask.
Short sessions: basics for everyone; deeper on risks and checking output for people who use AI with customers or personal data.
Keep the attendance list, the slides and the usage rule with a date. Repeat when tools or roles change.
Add the rule and the basics to onboarding so the measure stays current.
What a small company does not need.
The Commission's own Q&A stresses that measures depend on the context: the systems used, the risk and the people involved.
The practical reason to do it anyway.
The softer wording reduces the legal pressure, but the operational risks are unchanged: staff pasting personal data into free tools, or sending unchecked AI output to customers. A usage rule and an hour of training address exactly those risks.
If you want help, our in-company AI training (half day from €1,950, or €395 per person in an open session) includes a certificate and the documentation you can keep as your record. You can equally run it yourself with the plan above.
Where this comes from.
Not legal advice.
This guide is general information, checked against the sources listed, and not legal advice. Rules change; check the current text or ask a lawyer before you rely on it. Checked November 2026.
Common questions.
Does Article 4 apply if we only use ChatGPT?
Yes, if staff use it for work: the company is then a deployer of an AI system. The measures can be light for light use.
Is there a fine for not doing it?
The AI Act does not list a specific fine for Article 4. Supervision runs through national authorities, and a lack of measures could still count against you if something goes wrong. This is general information, not legal advice.
Did the Digital Omnibus remove Article 4?
No. As reported, it changed the obligation from ensuring a sufficient level to taking measures to support AI literacy. The duty to act remains.
Does a certificate from a course count?
It can be part of your record. What matters is that the measures fit the tools and roles in your company and that you can show what you did.
Want this in your business?
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