Is your team ready for the EU AI Act?
Article 4 requires all organisations using AI to ensure their staff have "sufficient AI literacy." Every company using AI tools — from ChatGPT to automated hiring systems — is in scope. Most haven't started.
What Article 4 actually requires
Article 4 of the EU AI Act requires providers and deployers of AI systems to ensure their staff and others acting on their behalf have "sufficient AI literacy" — proportionate to the context, the role, and the complexity and impact of AI systems in use.
This is not a checklist. It's not a certificate. Regulators will ask whether your training was:
- Role-appropriate — did each person receive training matched to how they interact with AI?
- Proportionate to risk — were staff using high-risk AI systems (Annex III) trained to a higher standard?
- Assessable — can you demonstrate that staff can apply the knowledge, not just recall it?
- Documented — do you have evidence of completion and comprehension?
Who is in scope
If your organisation does any of the following, Article 4 applies:
Why standard eLearning isn't enough
A generic "AI literacy" video module proves one thing: staff clicked through it. Article 4 asks for more. "Sufficient" means proportionate to the risk — and for staff using high-risk AI systems, the bar is higher than a completion timestamp.
Blend's AI Act scenario — "The Shortlist" — puts staff inside an AI-assisted hiring process where bias and transparency issues emerge. They make real decisions: whether to override the AI, how to document reasoning, what the candidate's rights are. Every choice is tracked. You get decision-level evidence, not a certificate.
The Shortlist
An HR team uses AI to screen job candidates. The system flags a qualified candidate as high-risk. Bias is suspected. You're in the room when the decision has to be made.
- AI risk classification under Annex III
- Transparency and explainability obligations
- Human oversight requirements
- Candidate rights under Article 86
Timeline to enforcement
AI Act entered into force. General provisions apply.
Prohibited AI practices (Article 5) took effect.
Article 4 AI literacy training must be implemented before enforcement begins. Most organisations haven't started.
National market surveillance authorities begin assessing AI literacy compliance. Penalties for providers: up to €15M or 3% of global turnover. Deployers: up to €7.5M or 1.5% of global turnover.
Start before it's urgent
Organisations that run a pilot now will have real completion data, identified training gaps, and documented evidence before the August deadline. Those that start in July won't.