Article 4 of the AI Act requires measures for AI literacy, not courses with certificates. What the Digital Omnibus changed and who controls it.
There is no AI training obligation with fixed courses, hour counts, or certificates. Article 4 of the AI Act requires companies that use AI systems to take measures to promote the AI literacy of their staff. Since the amendment by the Digital Omnibus, signed on 8 July 2026, the law explicitly states that no one has to guarantee a specific level of competence. Here you can read what the wording says, who supervises compliance, and which training is still worthwhile. As of: September 2026.
Article 4 of the AI Act is an obligation of effort: providers and deployers of AI systems take measures to support the AI literacy of their people. The AI Act does not provide a separate fine framework for Article 4, and a certificate is not required.
Article 4 obliges providers and deployers of AI systems to support the development of their staff's AI literacy, not to guarantee it. The new version from the Digital Omnibus Regulation (EU) 2026/1744 reads in paragraph 1:
"Providers and deployers of AI systems shall take measures to support the development of AI literacy among their staff and other persons dealing with the operation and use of AI systems on their behalf [...]. This obligation does not oblige providers or deployers to guarantee a specific level of AI literacy for any person."
A deployer is any company that uses an AI system under its own responsibility. Anyone working in an office with Copilot, ChatGPT, or AI features in their specialist software belongs to this group. Which measures are appropriate depends on people's prior knowledge, experience, and training, as well as the purpose of use. An accounting department that has invoices summarized needs something different from an HR department that pre-sorts applications.
Paragraph 2 also obliges the Commission and the Member States to support companies, especially SMEs, in this. The Commission publishes practical examples for this purpose.
The Digital Omnibus weakened Article 4 from an obligation to ensure to an obligation to support. In the original version of the AI Act companies were supposed to take measures to "ensure to the best of their ability" that their staff had a sufficient level of AI literacy. This version applied from 2 February 2025.
The reasoning for the change is set out in recital 8 of the Omnibus Regulation: strict obligations did not fit all companies and caused additional burden especially for smaller businesses, while AI literacy "should be a strategic priority independent of legal obligations and possible sanctions". The regulation was signed on 8 July 2026, published in the Official Journal on 24 July 2026, and entered into force on the third day after that.
The AI Act itself does not contain a separate fine framework for Article 4. Article 99 lists the obligations for whose violation the regulation sets specific maximum amounts, and Article 4 is not among them even after the Omnibus. For other violations, the Member States regulate sanctions themselves, with the new version of Article 99(1) explicitly naming warnings and non-monetary measures alongside fines, and wanting the interests of SMEs to be taken into account.
In Germany, the Bundesnetzagentur (Federal Network Agency) is the market surveillance authority. The Act Implementing the AI Regulation entered into force on 29 July 2026, according to the Federal Ministry for Digital Affairs. According to the Bundestag, it provides for fines of up to 50,000 euros for violations of certain cooperation and disclosure obligations, for example when someone refuses to provide information to the authority.
Booking training out of fear of a penalty is therefore the wrong reason. A lack of competence becomes relevant in a different way instead: if something goes wrong with an AI system, the question arises whether your people knew what they were doing.
No, the AI Act does not require the appointment of an AI officer. It still makes sense for someone in the company to keep an overview: which AI tools are used, with which data, and who has been trained. Whether this person is called AI officer, AI manager, or simply point of contact makes no legal difference. A certificate is not necessary either, as the European Commission clarifies in its questions and answers on AI literacy.
A training that starts from the tools and tasks of your company and that you briefly document makes sense. This satisfies Article 4 and helps in everyday work. What matters:
This is also how we structure our training days at NordFlux: one day on-site with your own documents, 1,000, 2,000, or 2,900 euros net for up to 4, 8, or 12 people, plus travel costs and expenses, see AI training for employees. Anyone who wants a point of contact for AI in every department will find that in the program AI Champions. The background on AI literacy is also covered in our article AI literacy training under Article 4, and the remaining AI Act deadlines are in the article What applies from 2 August 2026.
Not in the sense of mandatory courses. Article 4 of the AI Act requires companies to take measures to support the AI literacy of their staff. Since the 2026 Digital Omnibus, the law states that no specific level of competence has to be guaranteed. Training is the obvious measure, but no one prescribes its format or scope.
Yes. Article 4 applies to all providers and deployers of AI systems, regardless of size. How much effort is appropriate depends on the use and the risk. A craft business that uses Copilot for quote texts fulfills the obligation with considerably less effort than a company that uses AI for personnel decisions.
A brief internal record is enough: date, participants, content, and which AI tools were covered. According to the European Commission, a certificate is not required. Keep the records so that you can present them if the supervisory authority asks.
Under the Act Implementing the AI Regulation, in force since 29 July 2026, the Bundesnetzagentur is the responsible market surveillance authority. We are not aware of any published decisions specifically on Article 4 so far.
Founder of NordFlux. Spent four years automating processes at enterprise scale at Dräger, and now brings that depth to the mid-market — pragmatic and with full data sovereignty.
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We train your team on the AI tools you actually use and provide brief documentation right away. In the initial consultation, we clarify which roles need which content.
