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Article 4 of the EU AI Act: The AI Literacy Obligation Irish Employers Are Ignoring

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Ger Perdisatt

Founder, Acuity AI Advisory

Article 4 of the EU AI Act, as amended in 2026, requires organisations to take measures to support staff AI literacy. What that involves and how to record it.

Article 4 calls on providers and deployers to support the development of AI literacy among staff and others using AI on their behalf. The approach should reflect their knowledge, experience and working context.

The Commission’s current AI literacy Q&A explains the obligation as amended by Regulation (EU) 2026/1744 from 27 July 2026. It does not require any specific level of AI literacy of any individual, and it does not prescribe a particular course or certificate. A separate governance board is not required by Article 4. Requirements for people providing oversight of high-risk systems need separate consideration.

Plan around the work

List the AI tools and tasks people use. Identify the mistakes that matter: an invented source in a legal draft, an incorrect calculation in a report, or confidential information entering an unapproved service. Give each group guidance they can use to recognise and handle those situations.

Existing expertise matters. An experienced user may need a focused update on a changed tool, while someone new to AI may need a supported introduction. Do not assume attendance on the same course gives everyone the support they need.

Keep a practical record

Record what guidance was provided, who it covered and why it suited their responsibilities. Note questions and follow-up actions. These records help the organisation understand what it has done and where support is still needed. They are not a prescribed statutory template or a guarantee against enforcement.

Review the programme as tools and uses change. National market surveillance authorities supervise Article 4 from 2 August 2026; the general maximum fine for other AI Act breaches should not be presented as an automatic AI literacy penalty.

When outside help is useful

Outside support can help turn a list of tools into appropriate sessions and guidance, particularly where work crosses functions or professional obligations. It should start with the systems the organisation already uses.

Talk to Acuity about your team. Training packs and tailored materials are supplied only under an agreed commercial engagement.

eu ai actcomplianceireland