AI literacy under Art. 4 of the AI Act: what applies after the Digital Omnibus

Art. 4 of the AI Act has applied since 2 February 2025. In the original version, providers and deployers of AI systems had to take measures "to ensure, to their best extent" that their staff and other persons working with AI systems on their behalf have a sufficient level of AI literacy. As a result, many companies organised training or drew up rules for the use of chatbots and translation programs.

What Regulation (EU) 2026/1744 has changed

With the Digital Omnibus on AI, Regulation (EU) 2026/1744, the EU has reworded Art. 4. The amendment has applied since 27 July 2026. Providers and deployers now take measures to support the AI literacy of their staff and other relevant persons. The text expressly states that the obligation does not require a particular level of AI literacy to be ensured for any person. The Commission and the Member States are to support companies in this, especially small and medium-sized ones. The Commission is publishing practical examples for this purpose.

The same Omnibus has postponed the date of application for high-risk AI: to 2 December 2027 for systems under Annex III, and to 2 August 2028 for systems under Annex I.

What remains unchanged

The obligation itself continues to exist, and it still applies from 2 February 2025. The measures should be appropriate to the technical knowledge, experience and training of the employees and to the context of use. The Regulation does not prescribe a certificate or a particular form of training; internal briefings are just as acceptable as external courses. The Federal Network Agency (Bundesnetzagentur) recommends documenting the measures so that they can be demonstrated at any time. Art. 4 is not listed among the administrative offences in Art. 99.

What this means for businesses

If you have introduced training and rules since 2025, you do not need to withdraw anything. The new wording removes the pressure of having to prove a specific level of knowledge for each individual. However, a business that uses AI systems may not simply do nothing.

For a small business, this can be a short written policy: which AI tools are permitted, which data must not be entered (for example personal data of customers or employees) and who can help with questions. In addition, there should be an introductory briefing for everyone who uses these tools in their daily work, recorded in a simple list with the date and participants.