AI literacy under Article 4 EU AI Act: train your staff yourself, with slides and templates

What does Article 4 AI Act require?

Article 4 has applied since 2 February 2025 to providers and deployers of AI systems, meaning every company and every public authority that uses AI at work, including a general chat assistant. Regulation (EU) 2026/1744 (the “Digital Omnibus on AI”), in force since 27 July 2026, has amended Article 4:

Point	Version until 26 July 2026	Version since 27 July 2026
Obligation	ensure, to their best extent, that staff have a sufficient level of AI literacy	take measures that support the development of staff AI literacy
Level	“sufficient level”	no specific level owed for individual people
Who is obliged	providers and deployers	unchanged: providers and deployers
Benchmark	prior knowledge, experience, education, context of use, people affected	unchanged
New	–	the Commission and the Member States support organisations, especially small and medium-sized enterprises; the AI Board issues recommendations

In November 2025 the European Commission proposed removing the obligation on organisations altogether and obliging only the Commission and the Member States to promote AI literacy. That is not what happened: the obligation stays with you, it is just worded more mildly.

Who must be trained?

Everyone who works with AI systems on your behalf: employees, trainees and managers, but also agency workers and external service providers who operate your AI systems. Anyone who does not use AI does not need to be trained.

Do staff have to sign for the training?

No. Article 4 does not require a signature, nor a certificate or an exam. The European Commission considers internal documentation sufficient. The Bundesnetzagentur (the German Federal Network Agency) recommends recording the type, duration, content and participants. A signed confirmation of attendance is still an obvious form of proof. With the same signature, staff confirm that they know the AI rules of your organisation. The template covers both.

What happens if we do not train?

There is no specific fine for Article 4, either in the AI Act (Article 99) or in the German implementing act (KI-MIG, in force since 29 July 2026). In Germany, supervision lies with the Bundesnetzagentur. Liability matters more: if damage occurs because someone used AI incorrectly, a court will examine whether your organisation met its duty of care. What counts then is what you have documented.

How do we proceed?

1. Clarify needs: which AI systems, which roles, which data.
2. Set rules: permitted systems, data, contact person. A template is available in the guide AI policy for employees.
3. Train: 60 to 90 minutes with the slides, including exercises.
4. Confirm and document: signature, list of participants, plan a refresher.

What belongs in the basic training?

• What AI is: how a language model generates text and why it has no knowledge in the human sense.
• Strengths and limits: spotting invented information, checking results against the source.
• Data protection and confidentiality: which data may go into which system, professional secrecy, personnel data.
• Copyright and publication: checking AI results before they leave the organisation.
• Responsibility: the human decides, the AI delivers drafts. No decisions about people by AI alone.
• Good instructions: describe the task, context and desired result clearly.
• Your rules: permitted systems, contact person, reporting channel for errors and incidents.

What should we document?

• Needs: AI systems in use, purpose, groups of staff and types of data.
• Measure: date, duration, format, trainer and content, such as the version of the slides.
• Participants: list of participants or signed confirmations.
• Refresher: when the next training is planned and for whom.

How often must training take place?

There is no fixed interval. AI literacy is an ongoing process. A proven approach: basic training at rollout and for new staff when they join, a short refresher once a year, and a training session whenever a new system or new rules are introduced.

Is one training enough for everyone?

The basic training, yes. Those with more responsibility need more: administrators, people who build apps for others, and departments handling health, social or personnel data. Additional obligations apply to high-risk AI systems, see Identifying high-risk AI.

Does the works council or staff council have to be involved?

Often, yes. The works council has co-determination rights in the implementation of in-house training measures (§ 98 BetrVG, the German Works Constitution Act), and rules on the use of AI may also be subject to co-determination. Separate rules apply in the public sector and to church-run organisations.

Can we also book the training?

Yes. basebox trains your staff virtually or on site, using the use cases of your organisation: four hours, any number of participants. A virtual session costs €900, an on-site session €1,400 plus travel expenses. Booked training sessions also cover AI literacy under Article 4. Setup in your IT includes two training sessions.

Not legal advice, no liability: this guide and the templates are general information based on our knowledge as of the date stated. They do not replace legal advice and do not take the circumstances of your organisation into account. Have agreements and documents checked by your legal adviser before use.