WHO IS USING OR OPERATING THE AI?
Identify the provider or deployer, the staff involved, and other people using or operating AI systems on the organization’s behalf. The obligation is role- and context-sensitive.
Article 4 requires providers and deployers to take measures supporting AI literacy for relevant staff and other people using AI systems on their behalf. The practical challenge is showing that the measures fit the people, the system, the context and the risks.
The Commission states that Article 4 entered into application on 2 February 2025 and was later amended by the Digital Omnibus on AI in mid-July 2026. AI literacy remains an obligation for providers and deployers, while no single prescribed literacy level applies to every organization.
Start with the actual system, role, use case and evidence boundary. The same regulation can produce different obligations for different actors and systems.
Identify the provider or deployer, the staff involved, and other people using or operating AI systems on the organization’s behalf. The obligation is role- and context-sensitive.
Map literacy to the person’s role, technical knowledge, experience, education, training and the context in which the AI system is used. A generic annual course may not match the operational risk.
Preserve the system-specific risks, possible harms, limitations, human-oversight expectations, escalation routes and prohibited or restricted uses relevant to the person’s work.
Keep attributable records of who received what instruction, when, for which system or use case, what changed, and whether re-training or revalidation became necessary.
The goal is not merely to reach an answer. It is to preserve what facts, evidence, scope and limitations supported that answer at that time.
Start with the actual system, intended purpose, role and affected workflows instead of creating an organization-wide training claim detached from use.
State what the relevant people need to know to make informed use of the system and recognize opportunities, risks and possible harms.
Preserve the training, policies, instructions, assessments, acknowledgements or other evidence that supports the claimed literacy measures.
A new model, workflow, deployment context, role, authority boundary or material risk can make yesterday’s literacy record insufficient for today’s use.
Choose the smallest operating tier that fits the portfolio today. Upgrade when system count, team size or governance scope actually requires it.
Keep a living system-level evidence record with obligations, gaps, versions and revalidation state.
START EVIDENCE PASSPORT →Coordinate evidence, owners, documentation, incidents and team compliance work in one governed workspace.
START COMPLIANCE WORKSPACE →Operate broader high-risk, GPAI, FRIA, post-market and material-change governance across a growing portfolio.
START GOVERNANCE PRO →Run institutional governance with expanded users, authority workflows, examiner rooms and portfolio reporting.
START INSTITUTION →Use the free classifier to establish the system, intended purpose, possible actor role, EU exposure and unresolved facts. When continuing evidence infrastructure is needed, paid access begins at $19 per month. Independent human readiness review remains a separate service.
No. The Commission’s current guidance describes Article 4 as an obligation for providers and deployers of AI systems generally, not only high-risk systems.
Yes. Article 4 entered into application on 2 February 2025. The Commission also notes that Article 4 was amended by the Digital Omnibus on AI, which entered into force in mid-July 2026.
The Commission’s current Q&A says no specific or “sufficient” level is prescribed. Measures should be appropriate to role, knowledge, experience, training and the context in which the AI system is used.
The Regulation does not reduce AI literacy to a single certificate. From an evidence-governance perspective, organizations should preserve what measures were taken, for whom, for which system and why those measures were considered appropriate.
No. Software, course completion or a TA-14 record can support evidence continuity, but none of those by themselves establish a legal compliance conclusion.
Yes. The EU AI Act world can preserve system identity, role, obligation mapping, evidence, limitations, change and revalidation without claiming that the platform itself grants compliance.
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