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EU AI Act 28 April 2026 9 min read

AI Literacy EU AI Act: What Article 4 Requires From Businesses

Article 4 of the EU AI Act requires AI Literacy for all companies using AI. What it means, who must train, deadlines and how to comply with FUNDAE-subsidised training.

CS
Carlos Salgado CEO & Co-founder · Delbion

Since February 2025, all companies in the European Union that use artificial intelligence systems have a new obligation: ensuring their staff have the competencies needed to use that AI in an informed and responsible way.

This obligation comes from Article 4 of the EU AI Act, and it is known as AI Literacy. In this article I explain what it means exactly, who it affects, and how you can comply without overcomplicating things.

What Article 4 of the EU AI Act requires

Article 4 says something apparently simple: companies operating AI systems must ensure that their staff, from those who use it to those who supervise it, have an adequate level of understanding of how that AI works, what it can do and what its limitations are.

The regulation does not specify a particular training format or a minimum number of hours. What it requires is evidence that the company has taken steps to help its team understand the AI it uses.

What the law says: "Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and of any other persons dealing with the operation of AI systems on their behalf." (Art. 4, EU AI Act)

The key phrase is "to their best extent". This means training must be proportionate to how AI is used. A team using ChatGPT to draft emails is a very different situation from a department running automated decision-making algorithms on customers.

Who needs AI Literacy training

The obligation covers several categories of people within the organisation:

1
AI system operators

People who use AI-based tools in their daily work: from ChatGPT to AI-integrated CRM systems, predictive analytics tools or content generation platforms.

2
Supervisors and area managers

Those managing teams that use AI, who need to understand the implications, limitations and risks in order to make informed decisions.

3
Technical and support staff

IT, data and development teams that configure, maintain or integrate AI systems into the company's infrastructure.

4
Executives and decision-makers

C-suite and management teams that evaluate AI investments, approve projects or define the company's technology strategy.

In practice, if your company uses AI of any kind, and in 2026 that covers most companies, virtually everyone needs some level of AI Literacy.

Deadlines: when it applies

Article 4 entered into force on 2 February 2025. Unlike other parts of the EU AI Act that have longer timelines, the AI Literacy obligation is already active.

Date Event
1 August 2024 EU AI Act officially published
2 February 2025 AI Literacy mandatory (Art. 4), in force
2 August 2025 Bans on unacceptable-risk AI practices
2 August 2026 Full application for high-risk AI systems

What does this mean in practice? That since February 2025, authorities can ask any company to demonstrate it has taken steps to ensure staff AI Literacy. There is no formal grace period.

Fines for non-compliance can reach up to EUR 15 million or 3% of total annual worldwide turnover, whichever is higher. That is a real risk, but the good news is that complying is more straightforward than it seems.

What the training must cover

The EU AI Act does not prescribe a fixed syllabus, but it does indicate that training must be proportionate to context. Adequate AI Literacy training covers these areas:

  • Basic AI understanding: what it is, how it works conceptually, what it can and cannot do.
  • Responsible use: biases, hallucinations, model limitations, how to verify outputs.
  • Privacy and data protection: what information can and cannot be shared with AI tools, how to comply with the GDPR.
  • Security: security risks associated with AI use (prompt injection, data leakage, unauthorised use).
  • Applicable regulation: the EU AI Act, what risk categories exist and which ones affect the company.

The most effective training is not theoretical. It works better when it is grounded in the company's actual use cases: the tools the team already uses or plans to use. That way the learning is immediately applicable.

How to comply without disrupting the business

The most common concern I hear is: "How do I pull 30 people from their work for 10 hours of training?"

There are several ways to approach this without stopping operations:

  • Online format (e-learning): can be done on a flexible schedule, combining live sessions with asynchronous material.
  • Small groups: organising training in batches of 8 to 12 people to minimise the impact per department.
  • Two-hour sessions: splitting the 10 hours into 5 sessions of 2 hours each over one or two weeks.
  • Role-adapted content: not everyone needs the same depth. A common base training plus role-specific modules can work well.

The goal is for the training to be useful, not just a box to tick. If the team comes out of training using AI tools more effectively, the time investment pays for itself in productivity.

AI Literacy with FUNDAE subsidy

If cost is a concern, there is good news: AI Literacy training can be subsidised up to 100% through FUNDAE.

This means the cost of training your team can be zero euros if your company has available training credit. And most companies with employees on payroll do have it.

EUR 0 Net cost with FUNDAE
10 h Course duration
100% Subsidisable

At Delbion we have two courses that cover the requirements of Article 4:

Both are 100% subsidisable and cover the content the EU AI Act requires for AI Literacy.

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