EU AI Act compliance
Art. 4 AI Act competence duty: what you need to know now.
As of October 2026
Art. 4 of the AI Act has applied since 2 February 2025. The Digital Omnibus amended it, in force since 27 July 2026. Since 2 August 2026, national authorities supervise and enforce the rules; in Germany, under the KI-MIG (in force since 29 July 2026), this is as a rule the Bundesnetzagentur. Our step-by-step explainer.
What does Art. 4 of the AI Act actually say?
Providers and deployers of AI systems take measures to support the development of AI literacy of their staff and other persons operating or using AI systems on their behalf.
Art. 4 EU AI Act after the Digital Omnibus, paraphrased (not the legal text)
In plain language: if AI tools are used in your company, whether ChatGPT, Copilot, Claude or internal models, you are as a rule expected to take measures that help the people involved build AI literacy. Art. 4 requires measures that build AI literacy, but no specific level, no mandatory training and no certificate. The Bundesnetzagentur recommends documenting the measures well.
The European Commission writes in its AI Literacy Questions & Answers (last updated 27 July 2026): “There is no one size fit all when it comes to AI literacy and no strict requirements or mandatory trainings are imposed.” In practice that means: measures that fit role and risk, clear usage guidelines, and documentation that lets you answer an authority's question.
Who is affected by Art. 4?
Definitely affected
- Any business that provides AI systems or deploys them in its operations (e.g. Copilot licenses, ChatGPT Enterprise, internal models)
- Your staff and other persons operating or using AI systems on your behalf
- All industries, including non-tech
Exclusions
- Purely personal, non-professional use by private individuals: the deployer obligations do not apply (Art. 2(10)).
- AI systems and models developed and put into service solely for scientific research are outside the AI Act (Art. 2(6)).
Realistic assessment: If AI tools are used in your company, you should assume that Art. 4 applies to you, even without your own models.
What happens on non-compliance.
Art. 4
has no separate fine tier in Art. 99 AI Act or the KI-MIG
Art. 99 of the AI Act sets tiered fines: for prohibited AI practices (Art. 5), for the obligations listed in Art. 99(4), including the transparency obligations of Art. 50, and for incorrect, incomplete or misleading information to authorities. Art. 4 is not listed there, and the German KI-MIG does not set a separate fine for Art. 4 either. According to the European Commission, however, authorities can still impose penalties and other enforcement measures, following a proportionate approach.
Important: Since 2 August 2026, national authorities supervise the rules; in Germany this is, as a rule, the Bundesnetzagentur. If an authority asks, documentation shows which measures you have taken.
How to build AI literacy in a traceable way, in 90 days.
Step 1, Inventory
Which AI tools are currently in use? (Usually more than you think.) We provide an AI-inventory template.
Step 2, Risk categorisation
AI systems classified by risk tier (prohibited, high-risk, transparency obligations, minimal risk). The checklist asks whether you have assigned every AI system in use to a risk tier.
Step 3, Measure competence baseline
Who on your team knows what? Who needs what? Our assessment tool produces individual scores.
Step 4, Role-appropriate measures
No one-size-fits-all video, but measures that fit role and risk, for example role-based hands-on training on real tickets.
Step 5, Documenting the measures
Record training and other measures, your AI policy, usage guidelines and regular refreshers. The Bundesnetzagentur recommends documenting the measures well; according to the European Commission no certificate is needed, and an internal record is possible. That way you can answer an authority's question without improvising.
This roadmap is a practical recommendation, not a legal requirement. Our Agentic University transformation covers all five steps.
Common misconceptions about Art. 4.
Art. 4 only applies to high-risk AI.
False. Art. 4 addresses providers and deployers of AI systems, not only high-risk AI. It covers your staff and other persons operating or using AI systems on your behalf.
#ai-act-faq-1We don't build AI ourselves, this doesn't apply to us.
False. Art. 4 applies not only to providers but also to deployers, meaning businesses that use AI systems. If your employees work with ChatGPT, Copilot or Claude on the job, you should assume that Art. 4 applies to you, even without your own models.
#ai-act-faq-2We need mandatory training with a certificate.
No. Art. 4 requires measures that build AI literacy, but no specific level, no mandatory training and no certificate. The measures should fit role and risk. The European Commission writes in its AI Literacy Questions & Answers (last updated 27 July 2026): “There is no need for a certificate. Organisations can keep an internal record of trainings and/or other guiding initiatives.”
#ai-act-faq-3We have until 2027.
Not for Art. 4. Art. 4 has applied since 2 February 2025 and was amended by the Digital Omnibus, which entered into force on 27 July 2026. Since 2 August 2026, national authorities supervise and enforce the rules; in Germany this is, as a rule, the Bundesnetzagentur. The high-risk rules come later: from 2 December 2027 for Annex III systems and from 2 August 2028 for AI in regulated products (Annex I).
#ai-act-faq-4The effort is manageable.
It depends on how you use AI. There is no prescribed format, so you can start pragmatically. For mid-market firms without a structured L&D function, however, inventory, role-appropriate measures and their documentation tie up internal staff depending on how widely AI is used.
#ai-act-faq-5Is government funding available for AI training?
For longer programmes possibly, for short trainings no. In Germany, funding for employee training under § 82 SGB III (Qualifizierungschancengesetz) requires a measure of more than 120 hours, and both the provider and the measure must be approved under AZAV. Short trainings do not qualify, and neither does our licence on its own.
#ai-act-faq-6Resources.
The EU AI Act compliance checklist with 12 questions, fill it in once, and you can see where to follow up.
EU AI Act compliance checklist (PDF)
12 questions in 5 minutes.
- Structured self-assessment of your measures and how you document them.
- Delivered as a PDF by email, print-ready.
- Sent once, no spam sequence.
You have no time to lose.
Since 2 August 2026, national authorities supervise the rules. Our roadmap recommends taking and documenting AI literacy measures within 90 days.