AI literacy under Art. 4 of the AI Act

AI literacy under Art. 4 of the AI Act: what the Digital Omnibus changes

Margarita · Kosmo Team · 25 October 2026 · 4 min read

In shortAny company that uses AI must support the AI literacy of its staff. Article 4 of the EU AI Act has required this since February 2025. The Digital Omnibus on AI, in force since July 2026, rewrote the duty: companies must support the development of AI literacy but no longer guarantee a specific level for every person. The duty remains; it has just become more realistic.

What does Art. 4 of the AI Act require?

Art. 4 applies to providers and deployers of AI systems. Deployers also include companies that use AI tools in daily work, for example a chatbot, an AI writing tool or AI features in a CRM. Their staff should know enough about AI: how the systems work, where their limits and risks are, and how to use them responsibly.

What did the Digital Omnibus change?

The original version, in force since 2 February 2025, required companies to ensure, “to their best extent”, a sufficient level of AI literacy. The Digital Omnibus on AI replaced Art. 4:

Support instead of guarantee: companies no longer have to ensure a specific level for every person.
Duty of effort instead of result: what counts is what you can show you do.
More support for SMBs from the Commission and Member States.

Is AI literacy now voluntary?

No. The duty to take measures remains. Only the standard has changed: instead of a guaranteed result, a serious, documented effort counts.

What should small businesses do now?

Map AI use: which AI tools does your team use, officially and unofficially?
Train by role: take experience, prior knowledge and context of use into account.
Practice, not slides: training on the tools your team really uses.
Document: who got which training when, and which AI rules apply.
Use recognised frameworks, for example DigComp and the AI Literacy Framework.

How Kosmo Team helps

We map your AI tools, train your team hands-on and document the measures. More: AI training & workshops and GDPR & EU AI Act.

Frequently asked questions

Does Art. 4 apply to small businesses?

Yes. Art. 4 applies to all providers and deployers of AI systems, regardless of size. SMBs are, however, to receive particular support from the Commission and Member States.

Is it enough if my team only uses ChatGPT?

Anyone using AI tools at work is a deployer under the AI Act. You should then take AI literacy measures and document them.

Do my employees need a certificate?

No. Art. 4 does not require a specific certificate. What matters are suitable measures and their documentation.

What exactly did the Digital Omnibus change?

Companies must support AI literacy but no longer guarantee a specific level. A duty of result became a duty of effort.

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