EU AI Act Article 4 Amended: AI Literacy Requirements Updated
Rules regarding AI literacy in Article 4 of the EU AI Act have been updated via the Digital Omnibus. Companies are now required to take supportive measures rather than guarantee a specific level of knowledge.
What happened?
Through the EU's Digital Omnibus for AI (Regulation (EU) 2026/1744), which entered into force on 27 July 2026, Article 4 of the EU AI Act has been adjusted. Previous requirements that companies "ensure, to their best extent, a sufficient level" of AI literacy have been replaced. The new requirement mandates that providers and users of AI systems must instead "take measures to support the development" of AI literacy among their personnel.
Key facts
| Förordning | Förordning (EU) 2026/1744 |
|---|---|
| Ikraftträdande Digital Omnibus | 27 juli 2026 |
| Tillämpning Artikel 4 | 2 februari 2025 |
”The duty is no longer to 'ensure, to their best extent, a sufficient level' of literacy; it is to 'take measures to support the development' of literacy”
Why it matters
The adjustment clarifies that companies are not required to guarantee a specific, achieved level of knowledge for every individual employee. Instead, the focus has shifted to ensuring organisations actively offer educational initiatives and document the measures taken to strengthen AI literacy.
Who is affected?
The change concerns all organisations, providers, and users managing AI systems within the EU or targeting the EU market. This applies regardless of the AI system's risk classification and also includes third-country companies operating within the Union.
Impact on the EU
With the Digital Omnibus for AI (Regulation (EU) 2026/1744), requirements for AI literacy have changed across the entire EU. The amendment represents a shift from mandating guarantees of knowledge levels to requiring the implementation of active support measures. The European Commission and Member States have also been formally tasked with facilitating this work.
What else you should know
The analysis, authored by Erdem Mümtaz Hacıpaşaoğlu, highlights how companies outside the EU, such as Turkish firms operating in the European market, are also subject to the requirements of Article 4. Although knowledge levels no longer need to be guaranteed in the same manner, documentation of the support measures taken remains mandatory.
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