Art. 4 AI Act: The AI Literacy Obligation Is Already in Force

Art. 4 of EU Regulation 2024/1689 (AI Act) requires all organisations that use AI systems to ensure adequate artificial intelligence training for their staff. The obligation has been applicable since 2 February 2025 and applies to professional firms of all sizes.

This is not a formal box-ticking exercise: inadequate AI literacy exposes a firm to fines, professional liability and concrete operational risks.

What Art. 4 says exactly

The text of Art. 4 is surprisingly clear:

Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and of other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training, the context in which the AI systems are to be used, and the persons or groups of persons on whom the AI systems are to be used.

In short: those who use AI must understand what they are using. The depth of training must be proportionate to the role and the risk.

Who is obligated

The obligation applies to both providers (those who develop AI) and deployers (those who use it). For professional firms, the relevant category is that of deployer.

If even a single person in your firm uses ChatGPT, Microsoft Copilot, management software with AI features or any other AI-based tool, the obligation applies.

There are no exemptions based on size: a firm with 2 people has the same obligation as one with 200.

What "sufficient level" means

The AI Act does not prescribe a specific training programme, but it indicates the criteria for assessing sufficiency:

1. Basic technical knowledge: how AI works (without needing deep technical detail)
2. Awareness of limitations: hallucinations, bias, systematic errors
3. Context of use: specific risks of using AI in your profession
4. Impact on users: awareness of the effect that AI decisions have on clients and third parties

For an accountant, "sufficient level" means knowing why you cannot blindly trust an opinion generated by ChatGPT, which data is safe to enter into an AI tool and which is not, and how to document the use of AI in professional activities.

The penalties

Art. 99 of the AI Act provides for penalties for non-compliance. For violation of Art. 4, penalties fall under the second tier: up to €15 million or 3% of global turnover (for companies). The third tier -- up to €7.5 million or 1% of turnover -- applies to supplying inaccurate information to authorities.

Art. 99(6) provides an SME carve-out: for SMEs and start-ups, the applicable fine is the lower of the fixed amount or the percentage of turnover. Recital 168 clarifies that authorities must take into account the size of the organisation and apply proportionate penalties.

Beyond direct fines, inadequate AI literacy exposes a firm to:

• Professional liability: an error caused by incompetent use of AI can constitute negligence
• Collateral GDPR violations: those who do not understand how AI works cannot correctly manage personal data
• Reputational damage: a client who discovers the incompetent use of AI loses trust

How to comply: a 4-phase path

Phase 1: Competence assessment (1 week)

Assess the current level of AI knowledge across all staff:

• Who uses AI tools? Which ones? For what purpose?
• What is the level of awareness of the risks?
• Do any internal procedures or policies already exist?

Phase 2: Training programme (2-4 weeks)

Design a proportionate training path:

• Foundation level: for all staff (what AI is, how it works, limitations, risks, responsible use)
• Intermediate level: for those who use AI daily (prompt engineering, fact-checking, data management)
• Advanced level: for managers and partners (governance, compliance, strategic planning)

Phase 3: Delivery and documentation (1-2 days)

Deliver the training and document:

• Date, duration, topics covered
• Participants and their roles
• Materials used
• Verification test (recommended but not mandatory)

Phase 4: Continuous updating

AI evolves rapidly. Plan for updates:

• Quarterly: new tools, new features
• Semi-annually: regulatory changes
• Annually: full programme review

Our approach

The AI Literacy Workshop from Gitogi is designed specifically for professional firms and includes:

• An interactive half-day session (4 hours)
• Content calibrated to the profession (accountants, lawyers, HR consultants)
• Practical exercises with real AI tools
• A participation certificate that can be used for compliance documentation
• Reference materials and operational checklists

The training covers all the requirements of Art. 4 and is delivered by professionals with experience in both AI and regulatory governance.

The obligation is already in force

The AI literacy obligation under Art. 4 has been in force since 2 February 2025. Enforcement and the full sanctions regime apply from 2 August 2025, with high-risk system obligations following from August 2026. If you have not yet started an AI literacy programme, your firm is already technically non-compliant.

The AI Office Q&A published on 7 May 2025 clarified that there are no mandatory hours of training and no required certifications. What matters is that training is proportionate to the role, the risk and the context of use. This gives firms flexibility in how they fulfil the obligation, but it does not remove the obligation itself.

Start by assessing where you stand with the free AI Readiness Assessment, or contact us to plan the training path for your firm. For a broader understanding of the regulation that makes this obligation mandatory, visit our AI Act guide. Firms looking for ongoing training and certification support will find our Academy service the most structured option.