AI Literacy Training Under EU AI Act Article 4: What Irish Employers Need to Know

Article 4 of the EU AI Act requires providers and deployers of AI systems to take measures to support the AI literacy of their staff. For an employer in Dublin or anywhere else in Ireland, that means thinking about how the people who use AI at work are being equipped to do so. The duty has applied since 2 February 2025, and it was reworded by the Digital Omnibus on AI in July 2026. This guide sets out what the official sources say, what they do not say, and where our own suggestions begin.

A note on sources and dates: everything below comes from the European Commission's AI literacy Questions and Answers page (last updated 27 July 2026), the Commission's AI talent, skills and literacy page (last updated 27 July 2026), the Commission's AI Act Service Desk text of Article 4 (based on the EUR-Lex consolidated version as at 27 July 2026), Regulation (EU) 2026/1744 on EUR-Lex, and Irish government pages. This is general information, not legal advice. If your staff use AI tools that process personal data, our overview of the Data Protection Commission's guidance on AI and large language models is a useful companion.

What Article 4 says now

The AI Act was amended by Regulation (EU) 2026/1744, known as the Digital Omnibus on AI. EUR-Lex shows it as adopted on 8 July 2026 and published in the Official Journal on 24 July 2026. The Commission's regulatory framework page says it entered into force on 27 July 2026. The Commission's AI literacy Q&A page describes the change to Article 4 as taking effect in mid-July 2026, so the sources are not perfectly consistent on that detail.

The amended Article 4 has three paragraphs, as shown on the Commission's AI Act Service Desk and on EUR-Lex:

• Paragraph 1: providers and deployers "shall take measures to support the development of AI literacy of their staff" and of others dealing with the operation and use of AI systems on their behalf, taking into account factors such as technical knowledge, experience, education and training, and the context in which the systems are used. The paragraph adds that the obligation "does not require providers or deployers to guarantee any specific level of AI literacy of any individual."
• Paragraph 2: the Commission and Member States support and facilitate these efforts, particularly for small and medium-sized enterprises, and the Commission publishes practical examples of compliance on the single information platform.
• Paragraph 3: the AI Board adopts recommendations to promote AI literacy, taking European competence frameworks into account.

The Commission's Q&A page summarises the position this way: AI literacy remains an obligation, but no specific level is mandated.

Who Article 4 applies to

According to the Commission's Q&A page, the duty falls on providers and deployers of AI systems. The people whose literacy must be supported are the organisation's staff and "other persons" dealing with the operation and use of AI systems on its behalf. The page says these are not necessarily employees and gives contractors and service providers as examples. It also says clients may be relevant depending on the risk.

The page states that the AI Act applies to actors inside and outside the EU where the system is placed on the Union market, used in the Union, or where its use affects people in the EU.

Our reading, which is not a legal conclusion: an Irish employer that uses AI tools in its own business, for example a drafting assistant, a screening tool or a chatbot, is likely to be acting as a deployer, but you should check the Act's definitions (Article 3) for your own circumstances. We have not reproduced those definitions here because we have not relied on them in this article.

What Article 4 does not require

The Commission's Q&A page is unusually direct about the limits of the duty. It says:

• Article 4 "does not entail an obligation to measure the knowledge of AI of employees."
• There is "no need for a certificate." Organisations can keep an internal record of trainings and other guiding initiatives.
• No specific governance structure is mandated, so there is no requirement for an AI officer or AI governance board.
• There is no one-size-fits-all approach, and the Commission says no strict requirements or mandatory trainings are imposed on format.
• The AI Office does not impose requirements for specific sectors.

The same page says that simply relying on the instructions for use is not sufficient and that further measures are necessary. For deployers of high-risk AI systems, it notes that the obligation to train staff for human oversight remains.

What the Commission suggests organisations consider

The Q&A page offers suggested steps, which it presents as guidance rather than mandatory requirements. In summary: build a general understanding of AI, consider whether the organisation is a provider or deployer, assess the risks of the systems in use, and tailor actions to the knowledge of the people concerned and the context of use. It encourages covering legal and ethical aspects, including the AI Act itself.

The Commission also maintains a living repository of AI literacy practices compiled from organisations that pledged to the AI Pact and later others (the page was published on 4 February 2025 and last updated on 10 August 2026). The Commission states that copying a listed practice "does not automatically grant presumption of compliance with Article 4." The Commission's skills page refers to more than 40 initiatives in the repository.

Enforcement and penalties

The Q&A page says national market surveillance authorities in each Member State supervise and enforce Article 4, not the AI Office. It says authorities can impose penalties under national laws, proportionately, having regard to the nature and gravity of the infringement and whether it was intentional or negligent. It also says the AI Act "doesn't create criminal offences or a right to compensation." The Commission's skills page says national market surveillance authorities begin supervising and enforcing Article 4 on 2 August 2026, while the Q&A page gives both 2 August 2026 and 3 August 2026 in different places.

In Ireland, the Department of Enterprise, Tourism and Employment announced on 17 June 2026 that the Government had approved publication of the Regulation of Artificial Intelligence Bill 2026, which it describes as giving effect to the AI Act in Ireland and adding no obligations beyond the EU Regulation. The Workplace Relations Commission's AI Act page says the Regulation of Artificial Intelligence Act 2026 became law on 21 July 2026. We have not found an official Irish page that states which Irish authority supervises Article 4 specifically, and we have not read the Act's penalty provisions, so we do not state any amounts or procedures here.

A practical approach for Irish employers

The following points are our own suggestions, not legal requirements and not drawn from the Act.

• Start with a list of AI tools. Note which teams use which tools, including AI features built into software you already pay for. The Department of Enterprise's "The EU AI Act and my organisation" page (last updated 27 May 2026) also starts its suggested steps with mapping the AI you use.
• Match support to role. A finance team using a drafting assistant needs different support from an HR team using a screening tool. The Commission says the measures should reflect people's knowledge and the context of use.
• Cover the basics people actually need: what the tool does and does not do, checking outputs, what information must not be entered, and who to ask when something looks wrong. For personal data issues, see our guide to GDPR staff training for employers.
• Keep a simple record of what was provided and to whom. The Commission says an internal record is acceptable and a certificate is not needed.
• Include contractors and agency staff who use your tools, since the Commission's page refers to other persons acting on your behalf.
• Revisit the position when tools change, particularly if you adopt a system used for employment decisions, which may be treated as high-risk under other parts of the Act.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Do we need to give staff a certificate for AI literacy?

No. The Commission's Q&A page says there is no need for a certificate and that an internal record of trainings or other initiatives can be kept.

Do we have to test our employees' AI knowledge?

The Commission states that Article 4 does not entail an obligation to measure employees' knowledge of AI, and does not require a guaranteed level of literacy for any individual.

Does Article 4 apply to small businesses?

The sources we read do not exempt small businesses. Article 4(2) says the Commission and Member States support and facilitate AI literacy measures, particularly for small and medium-sized enterprises. The duty is framed around providers and deployers, so the question is whether your business is one of those in respect of the AI you use.

Who enforces Article 4 in Ireland?

The Commission says national market surveillance authorities enforce it. The AI Office of Ireland lists designated national competent authorities, including the Workplace Relations Commission and the Data Protection Commission for certain purposes, but the pages we read do not say which authority covers Article 4. Check the AI Office of Ireland for current information.

Does the duty cover contractors?

The Commission's page says the persons concerned include staff and other persons dealing with AI systems on your behalf, and mentions contractors and service providers as examples.

In short, Article 4 asks employers to support AI literacy in a way that fits their people and tools, without certificates, tests or a prescribed course. Check the Commission's pages and the AI Office of Ireland for updates, because both the EU rules and the Irish implementing arrangements have changed during 2026.