AI literacy under Article 4 of the EU AI Act: what a small business must do for staff who use AI
A proportionate SME plan
- List the AI tools staff use (chatbots, writing aids, note-takers, scoring tools).
- For each, note who uses it and the main risks (wrong answers, personal data, bias).
- Give a short briefing per role: what the tool is for, what not to put in, how to check output.
- Record date, attendees and material; repeat when tools or uses change.
What to cover
| Topic | Example |
|---|---|
| What AI is and is not | Outputs can be wrong; verify facts and figures |
| Data | No client personal data in tools without a lawful basis and contract |
| Your role under the Act | Deployer vs provider; disclosure duties for chatbots and AI content |
| Escalation | Who to tell when AI output causes a problem |
The Commission's Digital Omnibus proposal (November 2025) proposed changing how Article 4 works. Until any change is adopted and in force, read Article 4 as written and check the Commission's AI literacy Q&A for updates.
Common mistakes
- Thinking it only applies to AI companies. Deployers are covered.
- Buying a generic certificate and calling it done; the duty is about your context.
- No record of the training.
Frequently asked questions
When did Article 4 AI literacy start to apply?
On 2 February 2025, together with the prohibited practices in Article 5.
Does AI literacy apply to small businesses that only use AI tools?
Yes. Article 4 covers deployers as well as providers, taking into account context and proportionality.
Is a certificate required for AI literacy?
No. The AI Act does not require a certificate; the Commission's Q&A describes a flexible, context-based approach.
What should an SME keep as evidence?
A short record of the AI tools used, the briefings given, dates and attendees.
Official sources
Not tax or legal advice. This is a free explainer of public rules; deadlines and rules can change by notification, so confirm on the official portal or with your CA before you file. Last checked 22 Oct 2026.
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