What Art. 4 literally requires
Providers and deployers of AI systems must ensure that their staff and everyone else who handles AI systems on their behalf have a sufficient level of AI literacy. The key word is “ensure”: it's not enough for competence to somehow exist – the company has to actively make it happen, and be able to demonstrate that if questioned.
Since when does it apply, and when does enforcement start?
Art. 4 has already been applicable law since 2 February 2025 – unusually early compared to most other AI Act obligations. What's been missing so far is enforcement pressure: national market surveillance authorities (in Germany, the Bundesnetzagentur, via a new coordination and competence centre) only start actively checking this duty on 2 August 2026. For companies that means: the duty itself isn't new, but the real risk of being asked about it is rising sharply right now.
What counts as evidence – and what doesn't
The legislator deliberately prescribes neither content nor format – that creates flexibility, but also uncertainty. In practice, the duty usually boils down to a structured training measure. What doesn't cut it: handing out a PDF user manual without comment, or releasing a tool with no framing at all. What counts as a solid foundation in practice: documented training with recognisable content, proof of attendance, and a date – tiered by role, not a one-size-fits-all format.
Practice section: an evidence building block in three steps
First, tie training depth to the role: someone who only consumes a finished tool needs different content than someone building their own prompts, workflows, or models. Second, document the process – who attended, when, with what content, written down rather than just assumed. Third, repeat it whenever new tools are introduced or risks change – literacy isn't a one-time checkbox, it's an ongoing process. A completed, certified course like this one can serve as one building block of such evidence – but it doesn't replace a company-specific review or case-by-case legal advice.