What Article 4 says now
Regulation (EU) 2026/1744, known as the Digital Omnibus on AI, was adopted on 8 July 2026, published in the Official Journal on 24 July 2026, and entered into force on the third day after publication: 27 July 2026. It replaced Article 4 of the AI Act, Regulation (EU) 2024/1689, with three paragraphs:
- The duty. Providers and deployers of AI systems must "take measures to support the development of AI literacy of their staff" and of other people who operate or use AI systems on their behalf. The measures take account of people's technical knowledge, experience, education and training, the context the AI systems are used in, and the people they are used on. The duty does not require providers or deployers to guarantee any specific level of AI literacy for any individual.
- Support. The Commission and the Member States support providers and deployers, in particular SMEs. The Commission publishes practical examples of how to meet the duty on the AI Act's single information platform.
- Recommendations. The AI Board adopts recommendations, taking account of European competence frameworks, to promote AI literacy.
The date did not move. Chapters I and II of the AI Act, which include Article 4, apply from 2 February 2025.
Sources: Regulation (EU) 2026/1744, Article 1(5) and Article 4; Regulation (EU) 2024/1689, Article 113.
What changed on 27 July 2026
| Point | Before 27 July 2026 | From 27 July 2026 |
|---|---|---|
| The duty | Take measures to ensure, to their best extent, a sufficient level of AI literacy | Take measures to support the development of AI literacy |
| Required level | A sufficient level, to their best extent | No specific level required for any individual |
| Support | Not set out in the article | Commission and Member States support providers and deployers, especially SMEs, with practical examples |
| Who it covers | Providers and deployers of AI systems | Unchanged |
| Applies from | 2 February 2025 | Unchanged |
In plain terms, it is now a duty to take proportionate measures rather than a duty to reach a level. It still applies to every provider and deployer of AI systems, whatever the risk class. Guides written before 27 July 2026 quote the old wording, so check the date on anything you rely on.
What the European Commission's Q&A says
- No certificate is needed.
- An internal record of the training you provide is enough.
- National authorities supervise the AI literacy rule from August 2026.
Source: European Commission, AI literacy questions and answers (updated 27 July 2026).
Four questions to answer before you plan
The new Article 4 names the factors that measures should take into account. Turned into planning questions:
- Which AI systems do you provide or deploy? List the tools and systems in use, including general assistants staff use at work.
- Who operates or uses them on your behalf? Staff, and other people such as contractors who deal with the systems for you.
- What do those people already know? Their technical knowledge, experience, education and training.
- Where, and on whom, are the systems used? The context of use, and the people or groups the systems are used on.
The answers tell you which groups need what, which is the plan below.
A proportionate AI literacy plan by role
Article 4 asks for measures that fit your people and how they use AI. This is how we suggest structuring training. It is training guidance, not legal advice.
| Group | What they need | Course |
|---|---|---|
| Everyone who uses AI tools at work | What AI is and is not, safe use, your own AI policy | AI for Everyone (1 day) or ICP-FAI (14 hours, certified) |
| Frequent users | Hands-on practice with the assistants you use | Generative AI Mastery (2 days), Prompt Engineering Practitioner (1 day) |
| Leaders | Where AI creates and destroys value, what to fund and what to govern | AI for Leaders and Executives (1 day) |
| Policy, risk and compliance owners | The policy and control environment for AI use | AI Governance, Ethics and Responsible Use (1 day) |
| People who build or configure AI | Agents, automations and internal assistants | Agentic AI and Autonomous Workflows, Custom GPTs and Knowledge Bots, AI-Assisted Software Development (2 days each) |
| Functions | AI practice in their own work | HR, finance and risk, sales and marketing (2 days each) |
| Internal trainers | Sustaining adoption after the first wave | Train-the-Trainer: Facilitating AI Adoption (2 days) |
What to keep on record
The Commission says an internal record is enough. A simple one covers:
- the AI systems in use and the groups of people who use them;
- the training or other measures each group received, with dates and attendance;
- the materials used, and your AI use policy at the time;
- when you will review the plan, for example when you adopt a new AI system.
This list is our suggestion, not a legal template. ICP-FAI leads to an ICAgile credential, and our other courses award an Agile Visa Certificate of Completion, which you can file with that record.
Where ICP-FAI fits
ICP-FAI, ICAgile Foundations of AI, is our certified foundation: 14 hours of live, instructor-led training and a lifetime credential with no renewal fee. You can book seats on public cohorts, priced per seat and shown in your local currency on the course page, or run it as a private cohort for a whole team.
Financial services: DORA adds its own training duty
EU financial entities also fall under DORA. Its Article 13(6) makes ICT security awareness programmes and digital operational resilience training compulsory modules in staff training for all employees and senior management. That is a separate duty from AI literacy. See training for banks, insurers and financial firms.
Source: Regulation (EU) 2022/2554 (DORA).
Training supports your measures. It does not replace them.
No course can meet the Article 4 duty on its own. A sensible approach combines an AI use policy, training matched to each role, and a record of both. Our part is the training and the record of who completed it. For legal advice on your own obligations, speak to your advisers.
How the training runs
Every course is live and instructor-led, never a recorded lecture. Private cohorts run online across sites and time zones, or on site by arrangement. Delivered in English. Trainers for Arabic, Spanish, Bahasa Malaysia, German or French can be arranged for company cohorts on request. To buy for a team, see how to buy.
Frequently asked questions
Is AI literacy training mandatory under the EU AI Act?
Article 4 requires providers and deployers of AI systems to take measures to support the AI literacy of their staff. Training is the usual measure, but the article does not prescribe a format, and it does not require any specific level of AI literacy.
Do staff need an AI literacy certificate?
No. The European Commission's questions and answers on AI literacy say no certificate is needed, and an internal record of the training you provide is enough.
What changed in July 2026?
Regulation (EU) 2026/1744 replaced Article 4 from 27 July 2026. The duty changed from taking measures to ensure, to their best extent, a sufficient level of AI literacy to taking measures to support its development, with no specific level required. The application date, 2 February 2025, did not change.
Who does Article 4 apply to?
Providers and deployers of AI systems, whatever the risk class of the system. It covers their staff and other people who operate or use AI systems on their behalf.
When do national authorities start supervising Article 4?
According to the European Commission, national authorities supervise the AI literacy rule from August 2026.
Will your training meet our Article 4 duty on its own?
No training course can do that on its own. Our training supports your Article 4 measures and gives you a record of who learned what, and when.
Which course should all staff take first?
For a whole workforce, AI for Everyone (one day, private cohort). Where you want a certified foundation, ICP-FAI (14 hours live, lifetime ICAgile credential), bookable per seat or as a private cohort.
Last updated: 27 September 2026. Agile Visa is an ICAgile Member Organisation. 75,000+ professionals trained across 140+ countries since 2017.
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