What Article 4 of the EU AI Act actually requires before the August 2, 2026 deadline

What Article 4 says

Article 4 of the EU AI Act (Regulation (EU) 2024/1689) requires providers and deployers of AI systems to ensure, to their best extent, a sufficient level of AI literacy in their staff and other persons operating AI systems on their behalf.

This means any company whose employees use AI tools like ChatGPT, Copilot, or Claude at work is a "deployer" under the Act. The obligation applies to you.

When it applies

Article 4 has been in force since February 2, 2025. What changes on August 2, 2026 is that national supervision and enforcement begin. After that date, market surveillance authorities can ask companies to demonstrate their AI literacy measures.

What "sufficient level" means

The Commission's Article 4 FAQ, published in February 2025, clarifies that literacy must account for:

• The technical knowledge, experience, and education of staff
• The training they have received
• The context in which AI is used
• The persons affected by the AI system

A generic one-off training may not suffice for all roles. The FAQ expects a role-based, context-aware approach.

What you need to document

The FAQ confirms that internal records of trainings are sufficient. There is no mandated format, no certificate, and no accreditation requirement. You need:

1. A record of who was trained, when, and on what — a simple spreadsheet is enough
2. Evidence that training is role-based — different content for HR, marketing, developers
3. An AI-use policy — a written document covering approved tools, prohibited uses, and data rules

What you don't need

• No certificates or accreditations
• No external training provider
• No learning management system (LMS)
• No specific number of training hours

Free template

You can download a free AI training record log to get started. It's a spreadsheet with columns for name, role, module, date, format, trainer, and refresher due date.