Establish an AI literacy programme for staff and contractors under AI Act Article 4 as amended by the AI Omnibus

Documented steps

1. Confirm your role. Article 4 applies to providers and deployers of AI systems. Organisations that both build and use AI systems carry the duty in both capacities.
2. Get the post-Omnibus wording of Article 4 from the amending regulation rather than from older guidance, because the article was replaced: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ%3AL_202601744
3. Understand the change in standard. The original Article 4 required providers and deployers to ensure a sufficient level of AI literacy. The amended text frames the duty as taking measures to support the development of AI literacy among staff and other persons dealing with the operation and use of AI systems on their behalf. The duty remains with providers and deployers; the standard is softer.
4. Scope the population: own staff plus contractors, agency workers and service providers who operate or use AI systems on your behalf.
5. Calibrate to context as Article 4 requires: the technical knowledge, experience, education and training of the persons concerned, and the context in which the systems are used, including the persons or groups affected.
6. Build a layered programme: baseline AI awareness for all staff; role-based modules differentiated by whether staff touch prohibited-practice-adjacent, high-risk or general-purpose AI systems; dedicated training for anyone performing human oversight of a high-risk system; and a channel for staff to escalate AI risk concerns.
7. Check the Commission's practical compliance examples and the AI Board's recommendations as they are published under Article 4: https://digital-strategy.ec.europa.eu/en/policies/ai-talent-skills-and-literacy
8. Retain evidence. No certification is mandated, so curricula, attendance records, materials and dated version history are the proof that measures were taken.
9. Re-run the gap analysis when new AI systems are adopted, new categories of contractors are engaged, or the Commission publishes new examples.
10. Note the timing: Article 4 has applied since 2 February 2025, so this is a live obligation and not one deferred by the AI Omnibus.