Yes, to a reasonable extent. A company deploying AI must, under Article 4 of the AI Act, take measures to promote AI literacy among its employees and other persons who use AI on its behalf. Regulation (EU) 2026/1744 relaxed the obligation with effect from 27 July 2026: it no longer requires a sufficient level of literacy to be ensured and expressly does not require any specific level to be guaranteed for any individual. The obligation nonetheless remains, and it is worth documenting the measures taken.
The team uses chatbots for text, translations and analysis, developers work with a coding assistant, and HR is trying out a tool for sorting CVs. Management asks whether the AI Act requires compulsory training and certificates. After the July 2026 amendment the obligation remains, but its content is milder.
How Article 4 reads after the amendment
The original wording, in force from 2 February 2025, required providers and deployers of AI systems to take measures to ensure, to their best extent, a sufficient level of AI literacy. Regulation (EU) 2026/1744 replaced the article, and from 27 July 2026 it provides:
Providers and deployers of AI systems shall take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be used. This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual.
— Article 4(1) of Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744
A deployer is any company that uses AI in its activities, not only one that develops it. The obligation therefore also applies to an office whose only AI tool is a licensed chatbot. Under the new paragraph 2, the Commission and the Member States are to support companies in complying, particularly small and medium-sized enterprises, and the Commission is to publish practical examples of how to meet the obligation on the single information platform.
What literacy means
The Regulation defines it as the skills, knowledge and understanding that allow AI systems to be deployed on an informed basis and awareness to be gained of their opportunities, risks and the harm they may cause (Article 3, point 56). It is not a technical education, nor a certificate. An employee should know what the tool may be used for, what data does not belong in it, why the output has to be checked and to whom errors are to be reported.
The extent of the measures follows the context. An assistant who has an email rephrased needs brief rules. An HR officer working with a tool that assesses candidates needs more, because the output affects a decision about a person. For high-risk systems, which include recruitment, the specific requirement of Article 26(2) will also apply from 2 December 2027: human oversight must be assigned to persons with the necessary competence, training and authority.
Why the measures are worth documenting
Relaxation does not mean that doing nothing is enough. On inspection, the duty to “take measures” is demonstrated by what the company has done: an internal policy on the use of AI, a short induction briefing, a record of attendance, a list of approved tools. The same steps also help with the GDPR. Under Article 32(4) GDPR, a controller must ensure that persons with access to personal data process them only on its instructions. Rules on what data does not belong in public chatbots therefore serve both instruments at once.
We regard three things as a sensible minimum for an ordinary company: a one-page policy setting out what is and is not permitted, short role-specific training, and regular updating as new tools appear. When the AI Act applies to a company and what deadlines run is explained in when the AI Act applies and to whom; obligations concerning customer-facing chatbots are discussed in whether you must tell customers that a chatbot is answering.
How we can help
We map which AI tools your company uses, prepare an internal policy and short role-based training, and document them so that they stand up to inspection. All of this forms part of our AI Act and artificial intelligence deployment service. If you already have rules in place, send them to us; we will tell you what needs adjusting after the amendment.
This answer provides general information on the law as at 12 September 2026. It does not constitute legal services or replace an assessment of an individual case. The details of your situation may differ. Book a consultation to discuss them.
