# What AI literacy actually requires > Justas Butkus is a fractional AI officer based in Vilnius, Lithuania, founder of AINORA, MB and of Impetora, and a graduate of ISM University of Management and Economics. Justas Butkus is a fractional AI officer based in Vilnius, Lithuania, working with mid-market companies across the UK and EU. He advises on AI governance and literacy obligations and builds the production AI systems those obligations apply to. **Article 4 of the EU AI Act requires providers and deployers to take measures that support the development of AI literacy among people operating AI systems on their behalf. It has applied since February 2025 and was replaced on 27 July 2026 by the Digital Omnibus, softening it from a duty to ensure a sufficient level to a duty of effort. There is no mandated curriculum, examination or certificate.** Canonical: https://justasbutkus.com/ai-training/ Last updated: 2026-08-01 --- ## What the obligation says Article 4 is short, and it changed recently. Regulation (EU) 2026/1744, the Digital Omnibus on AI, replaced it in full with effect from 27 July 2026. Providers and deployers must take measures that **support the development of** AI literacy among their staff and other people operating AI systems on their behalf, including contractors. The wording matters. The original text required you to take measures to ensure, to your best extent, a *sufficient level* of AI literacy. The current text does not: it is a duty of effort, and it does not require you to guarantee that any individual has reached any particular standard. The measures must still reflect those people's technical knowledge, experience, education and training, the context of use, and who the systems are used on. Most published guidance still quotes the repealed wording. If a supplier is selling you compliance against a "sufficient level" standard, they are working from a version of the article that is no longer in force. ## What it does not require This is where most of the confusion, and most of the selling, happens. - **No mandated curriculum.** The Act does not specify content. - **No guaranteed outcome.** Since 27 July 2026 the duty is to support development, not to certify that anyone has reached a standard. - **No examination or certification.** There is no exam to pass and no certificate that constitutes compliance. - **No appointed role.** Article 4 does not require an AI officer, a training manager, or any named position. - **No single standard for everyone.** A uniform course delivered to all staff regardless of role is arguably the wrong shape, not the safe one. > If a supplier tells you the AI Act requires certified AI training, ask them to point at the provision. They will not be able to, because it does not exist. The obligation is real; the specific product being sold against it usually is not the only way to meet it. ## What compliance looks like in practice 1. **Establish who operates AI systems on your behalf** — Staff and contractors. This list is usually longer than expected once unapproved tools are counted. 2. **Segment by what they actually need to understand** — Someone acting on an AI output needs to understand its failure modes. Someone building the system needs considerably more. 3. **Cover capabilities, limitations and oversight** — What these systems are good at, how they fail, why outputs need checking, and when to escalate. 4. **Make it specific to the systems you actually run** — Generic AI awareness training is weak evidence. Training on the systems in your own business is strong evidence. 5. **Document what you did** — What was delivered, to whom, when, and the reasoning for the segmentation. Documentation is the evidence, not the training itself. ## Sources, and a necessary caveat - Regulation (EU) 2024/1689 (the AI Act), [Article 4](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024R1689). - Regulation (EU) 2026/1744, the Digital Omnibus on AI, published 24 July 2026 and in force 27 July 2026, which replaced Article 4 in full. > This page is general information about the Regulation as it stands on the date above. It is not legal advice, it does not account for national implementing rules, and it does not replace advice on your specific circumstances. ## Why the documentation matters more than the course Article 4 has no prescribed format, which means there is no box to tick that proves compliance. What you are left with is the ability to demonstrate a reasoned, proportionate approach. In practice the question does not usually arrive from a regulator. It arrives in a procurement questionnaire, an insurer's renewal form, or an enterprise customer's due diligence pack, and it is phrased as "describe your AI literacy measures". A company that can answer with a segmented, documented, systems-specific approach clears that gate. A company holding a generic completion certificate often does not. ## Frequently asked questions ### Does the EU AI Act require AI training for staff? It requires providers and deployers to take measures that support the development of AI literacy among staff and contractors operating AI systems on their behalf. Since the Digital Omnibus replaced Article 4 on 27 July 2026 this is a duty of effort rather than a duty to ensure a sufficient level. Training is the usual way to meet it, but no specific training is mandated. ### Is there a required AI literacy certification? No. Article 4 prescribes no curriculum, no examination and no certificate. Any supplier claiming a certification is required by the Act is misrepresenting it. Documented, proportionate, role-appropriate measures are what the obligation asks for. ### When did Article 4 come into effect? It has applied since 2 February 2025, and was replaced in full on 27 July 2026 by Regulation (EU) 2026/1744, the Digital Omnibus on AI, which changed it from a duty to ensure a sufficient level into a duty to take measures supporting AI literacy. ### Does this apply to contractors as well as employees? Yes. The obligation covers staff and other persons operating AI systems on your behalf, which includes contractors and service providers. ### How do we evidence compliance? Document who operates AI systems, how you segmented them by need, what was covered, when it was delivered, and the reasoning. The documentation is the evidence, since the Act prescribes no format that could otherwise serve as proof. ## Related - [Article 50 and AI callers](/eu-ai-act/voice-agent-disclosure/) — What must be disclosed when AI speaks to customers. - [When the board asks for an AI plan](/board-ai-plan/) — Where governance fits in the paper. - [EU AI Act in depth](https://impetora.com/eu-ai-act/overview) — Risk classification, conformity assessment, ISO 42001 mapping. ## If a questionnaire has just asked you about this That is usually the real trigger, and it is a bounded piece of work with a clear finish line. Contact: justas@ainora.lt · [LinkedIn](https://www.linkedin.com/in/justas-butkus/) ## Other languages - EN: https://justasbutkus.com/ai-training/ - LT: https://justasbutkus.com/lt/di-mokymai/