Did the EU AI Act remove the requirement to train employees who use AI?
No.
But the requirement has changed.
The EU Digital Omnibus amended Article 4 of the AI Act in July 2026. Businesses are still required to take measures supporting the development of AI literacy among staff and others using AI on their behalf.
What changed is the standard they are expected to meet.
What changed in Article 4?
The original Article 4 required AI providers and deployers to take measures to ensure, to their best extent, a “sufficient level” of AI literacy.
Regulation (EU) 2026/1744 replaced that wording.
The current rule requires providers and deployers to take measures that support the development of AI literacy.
It also now expressly states that businesses do not have to guarantee any specific level of AI literacy for an individual employee.
That is an important simplification.
It does not remove the obligation.
Does every employee need AI training?
Not necessarily the same training.
Article 4 remains intentionally proportionate.
Businesses should consider:
- employees' existing technical knowledge and experience
- their education and training
- the context in which AI is being used
- the people or groups potentially affected by that AI
This means a marketing employee using generative AI to draft social posts may need different knowledge from an HR manager using AI-assisted candidate screening.
A software engineer developing AI functionality may need something different again.
The regulation does not prescribe one mandatory course, certificate or number of training hours.
Is AI literacy enforceable now?
Yes.
Article 4 has applied since 2 February 2025.
The European Commission confirms that the supervision and enforcement framework is now applicable.
Ireland has also established the AI Office of Ireland as the central coordinating body for national implementation, working through Ireland's distributed network of competent authorities.
Businesses should therefore avoid treating AI literacy as something that only matters when the high-risk AI rules arrive in 2027.
It is already part of the applicable AI Act framework.
What does practical compliance look like?
For many businesses, Article 4 does not need to become a complicated training programme.
A proportionate approach might include:
1. Identify who is using AI
Start with actual workplace use.
This includes approved business systems, AI features inside existing software and generative AI tools employees may be using directly.
2. Train by role and risk
Do not give everyone the same generic presentation.
Employees using AI for writing may need guidance on verification, confidentiality and hallucinations.
HR teams may also need to understand bias, automated decision-making and high-risk AI.
3. Establish clear AI usage rules
Training works better when employees know what the organisation permits.
Define approved tools, restricted data, verification expectations and situations that require human review.
4. Keep evidence of what you have done
Record training sessions, guidance provided, policies issued and relevant staff communications.
The AI Act does not prescribe a particular certificate, but businesses should still be able to demonstrate the measures they have taken.
5. Review literacy when AI use changes
AI literacy should not be treated as a one-off exercise.
If a team moves from using AI to draft emails to using it to evaluate people or automate decisions, the risk and required knowledge change.
Blanche perspective
The amended Article 4 makes the objective clearer.
Businesses are not expected to turn every employee into an AI expert.
They are expected to make reasonable, context-specific efforts so people understand the AI they use and the risks that matter in their role.
For most organisations, the practical combination is straightforward:
AI inventory + AI usage policy + role-based AI literacy.
That creates a much stronger foundation than sending every employee the same online course and considering AI governance complete.
Sources
Primary and authoritative sources used for this Insight.
- EUR-Lex: Regulation (EU) 2026/1744 of 8 July 2026, replacing Article 4 (binding law; in force 27 July 2026)
- EUR-Lex: consolidated AI Act, Article 4, as amended on 27 July 2026
- European Commission: AI Literacy Questions & Answers (non-binding explanatory guidance)
- European Commission: AI Omnibus enters into force, 27 July 2026 (implementation information)
- Department of Enterprise: EU Artificial Intelligence Act (official Irish implementation information)
- Department of Enterprise: AI Office of Ireland established, 30 July 2026 (official Irish implementation information)