Article 4 Has Been Live Since February 2025. Is Your AI Literacy Programme Real?

Article 4 of the EU AI Act rarely makes headlines, which is odd, because it is one of the few obligations that has already been enforceable since 2 February 2025. It requires providers and deployers to ensure a sufficient level of AI literacy among their staff and anyone operating AI systems on their behalf.

The trap is the word sufficient. There is no single standard that applies to everyone, because sufficiency depends on what a person actually does with AI: how close they sit to the system, how much decision authority they hold, and who is affected by the output. A one-size training video does not meet that test.

The only model that holds up is tiered and role-based. You calibrate the depth of literacy to proximity and consequence, so a board director, a compliance officer, and a front-line operator each get something different. The biggest gap in most organisations is not the boardroom or the data science team, it is the operator layer, the people who carry day-to-day accountability for AI-assisted decisions and have had the least targeted training.

The board is not exempt, and this surprises people. Executive and board-level literacy is a regulatory reality, not a nice-to-have, because personal liability under Articles 5 and 26 attaches to those who authorise AI deployments. A director who signs off on a high-risk system without understanding it is exposed.

For internally built systems at the higher tiers, generic content will not do. Operators overseeing a bespoke model need training tied to that system, its failure modes, and the specific decisions it informs. Generic material teaches awareness, not oversight.

The good news is that evidencing compliance does not have to be heavy. The right artefacts, built into processes you already run, will satisfy a national competent authority without creating a parallel bureaucracy. What matters is that the records map literacy to role and show the programme is live and maintained.

Our whitepaper, Article 4 in Practice, lays out the tiers, the operator gap, the board obligation, and a documentation approach you can actually sustain. AI literacy is not a campaign you run once. It is a standing capability, and the deadline for starting passed over a year ago.