Article 4 of the AI Act: what AI training your team needs

Since 2025, every company that uses AI must train its team. What changed with the Digital Omnibus, who enforces it, and how an SME can comply.

By Magnus JernUpdated

As of 2 February 2025, any company that uses AI tools in their work (ChatGPT, Copilot or Gemini included) must implement measures to ensure that their team is aware of how to use them. This is the requirement of Article 4 of the EU AI Act. Since July 2026, after the Digital Omnibus reform, it is no longer about reaching a certain level, but about taking action and being able to prove it. In an SME, this can be as simple as a short training session, a written usage policy and a record of who was trained.

What Article 4 is about

What Article 4 is about is AI literacy: skills, knowledge and understanding that allow people to use AI systems with judgment, being aware of the opportunities, the risks and the harms they can generate (Article 3 of the regulation defines it that way).

The original text, as of 2 February 2025, required providers and deployers to ensure, "to their best extent", that their staff and those who use AI systems on their behalf have a sufficient level of AI literacy.

But the wording was amended by Regulation (EU) 2026/1744, Digital Omnibus, published on 24 July 2026 and in force since 27 July:

  • Now a company must implement measures to foster AI literacy among its staff and those who use AI on its behalf.
  • The article clarifies that it does not require a specific level to be guaranteed for each person.
  • The European Commission and the member states must support these efforts, especially those of SMEs.

In other words, it is no longer a duty of results, but a duty of means. But it is still a duty.

Is your company affected?

Almost certainly. The regulation defines as a deployer anyone who uses an AI system under their own authority (except for personal, non-professional use). So, if you have someone on your team who uses an AI tool to write emails, prepare proposals or create images for a campaign, your company is the deployer of that tool.

There is no exemption based on the size of the company. A company with 5 people has the same duty as one with 500 people, even if the reasonable way to comply is much simpler. It also applies to people who use AI on your behalf, such as freelancers or contractors.

Who enforces it and what happens if you don't comply

Since August 2026, the national authorities can monitor compliance with Article 4. In Spain, the main authority is the AESIA (Agencia Española de Supervisión de la Inteligencia Artificial).

The penalties are determined by each member state. In Spain, the organic law bill to establish them lapsed on 6 October 2026, when the Cortes were dissolved, so a new text will have to be created. Currently, the most real risk is not a fine for Article 4, but the possibility of having an inspection, a customer complaint or a data leak, and not being able to show what you have done to ensure that your team uses AI carefully.

What training does your team need?

There is no official certificate, and there is no minimum number of hours. In the questions and answers on Article 4, the European Commission recommends that the training be adapted to what each person does with AI and what they already know, and that the risks of the tools used by the company be taken into account.

A practical way to organise it, by role (hours are indicative, not set by the regulation):

Role What they should know Suggested time
The whole team What generative AI is and what it gets wrong, what data is never entered, that every output must be reviewed before use, the company's policy 1 to 2 hours, at the beginning and when joining
People who publish content (marketing, agencies) Also: when you must disclose that an image, audio or video is artificial, image rights and copyright 1 more hour
People who use customer or employee data Also: GDPR applied to AI, why AI is not left to make decisions about people 1 more hour
People who choose or configure the tools Also: how to evaluate a provider, the data processing agreement, where data is processed 2 more hours

How an SME can comply in 5 steps

  1. Take stock of the AI tools you use. This includes those that people use on their own initiative: according to an OpenAI study of 1,000 Spanish SMEs, 70% of their executives say their staff already use AI on their own initiative.
  2. Determine which tools are authorised and for what, and put it in writing. An AI usage policy is the basis of the training: which tools, with which data, who reviews the output. 39% of Spanish SMEs still do not have one.
  3. Train each person according to their role, using the table above as a starting point.
  4. Record what you do. A simple record is enough: who was trained, when, with what content, and that they read the policy. This is what you can show if asked.
  5. Review it every year, and when the tools change or someone joins.

Common mistakes

  • Thinking it only affects those who develop AI. Article 4 also applies to those who use it.
  • Buy a certificate and call it a day. There is no official certificate; what matters is that the training is tailored to your company and documented.
  • Banning AI. It rarely works: people continue to use it from personal accounts, and the company loses control of its data.
  • Training once and forgetting about it. The tools change every few months, and so does the team.

How P30 can help you

Training is easier when the whole team uses the same authorised tool. In P30, the company works in its own workspace, with roles and permissions, instead of personal accounts. Your data is stored in the EU and never used to train models. And our team helps you roll it out.

For the rest of the AI Act (the calendar, the fines, what was delayed), check our guide to the EU AI Act in 2026.

Sources

FAQ

Frequently asked questions

Is AI training for employees mandatory?
Yes, if your company uses AI systems in its professional activity. Article 4 of the EU AI Act has required AI literacy measures since 2 February 2025. Since July 2026 it doesn't require a certain level, but it does require action.
Do I need an official certificate?
No. There is no official certificate, and there is no minimum number of hours. What you should do is record what training you give, to whom and when.
Does it apply to a 5-person company?
Yes. Size does not exempt you, although in a small company complying is simple: an initial session, a written usage policy, a record.
What happens if I don't comply?
Since August 2026, the national authorities, such as AESIA in Spain, can monitor compliance. The penalties depend on national law; in Spain, the bill that established them lapsed in October 2026, when the Cortes were dissolved. The prudent thing to do is to be able to show what measures you have taken now.
Does it count as training if the team already uses AI every day?
Not on its own. Using a tool is not the same as knowing its limits and risks. You need specific training, and to be able to show it.

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