AI literacy under Article 4 of the EU AI Act: what SMEs in Malta should do now

Last checked 13 Oct 2026

Short answer. Since 2 February 2025, every provider and deployer of an AI system must take measures to support the AI literacy of its staff. That includes a business whose staff only use ChatGPT or a translation tool. No certificate is needed: the European Commission says an internal record of trainings or guidance is enough. National supervision and enforcement apply from August 2026.

What does Article 4 say?

Article 4 asks providers and deployers of AI systems to take measures to support the AI literacy of their staff and of other people who use AI on their behalf (a contractor, for example). Since the 2026 Digital Omnibus amendment no specific ‘sufficient level’ is mandated, but the obligation remains.

Applies since 2 February 2025, to any AI system, not only high-risk AI.
No certificate needed; an internal record of trainings or other guidance is enough.
No mandatory knowledge test and no mandatory AI officer.
National market surveillance authorities supervise and enforce it from August 2026.

Who supervises it in Malta?

The European Commission’s list names the Malta Digital Innovation Authority (MDIA) as the single point of contact for market surveillance in Malta. Check the current position on the European Commission list.

What to do this week

List your AI tools. Write down every AI system and AI feature your business uses or offers (chatbots, writing assistants, translation, AI inside your accounting or HR software).
Brief your staff. For each tool, explain what it may be used for, its risks (such as made-up answers) and what must not go into it (such as customers’ personal data).
Keep a dated record. Note who received which briefing or training, and when. That record is your evidence.

Free tools

EURO AI Register: free for your first AI system, with a printable Article 4 record. Your data stays in your browser.
Free risk-tier checker: estimate in a few minutes which risk tier an AI system is likely to fall into.

Pricing

The Register is free for one AI system. Membership is US$19 a month and unlocks unlimited systems. The price is set in US dollars; the euro amount depends on your bank’s or card’s exchange rate.

Official sources

Not legal advice. This is an independent explainer, not a publication of the EU or any government. The Register is a record-keeping tool, not proof of compliance. Last checked 13 Oct 2026.

Prepared by the Unadhi EURO AI team. AI-built, human-reviewed. Not legal advice.