Is AI training mandatory? What Article 4 of the EU AI Act requires

The wording

Paragraph 1 of Article 4, in the amended version, reads: "Providers and deployers of AI systems shall take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be used."

It continues: "This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual." (EU AI Act Service Desk, Article 4, retrieved 8 October 2026.)

What this means for your company

If your company uses AI systems — for example a text assistant that employees work with — you are a deployer. The provision asks for measures that fit your people: their knowledge, their experience, their tasks and the context in which the AI is used. A person who prepares standard replies needs something different from a person who approves the use of a new tool.

It is sensible to document who learned what, because then you can show which measures you took. The text does not require a certificate, and it does not set a level that each person must reach.

Older wording still circulates

Older texts quote the earlier wording, which asked to "ensure" a sufficient level of AI literacy — for example the fact sheet of the Bundesnetzagentur from November 2025. This wording was changed by the Digital Omnibus on AI. If you read a statement that you must guarantee a level of AI literacy for every employee, check it against the current text above.

Support for small companies

Paragraph 2 of the amended Article 4 says that the Commission and the Member States shall support and facilitate the efforts of providers and deployers of AI systems, in particular SMEs, in fulfilling their obligations.

Who is responsible in Germany?

In Germany the Bundesnetzagentur is the market surveillance authority, contact point and complaints body for the AI Regulation. This follows from the law on market surveillance and promotion of innovation for artificial intelligence (KI-MIG), which entered into force on 29 July 2026, as stated in the Bundesnetzagentur's press release of the same day.

How we help

Training by role with documentation is part of ACTUS, our chamber for adoption. We do not use fear in our advertising, and we make no promise of a certificate. This guide is general information and not legal advice; whether a particular measure is sufficient in your case is a question for your own legal adviser.