AI literacy Commission Q&A: the 10 answers that matter
The European Commission's AI literacy Q&A answers the questions most organizations ask about Article 4 of the EU AI Act. In short, you need no certificate, no knowledge test and no AI officer. You do need measures that fit your people's roles and the risks of their AI tools, including contractors working for you.
Picture a tender form asking for "AI literacy certificates for all staff". Article 4 requires none, but you still have to show what you did. Here are the 10 answers that matter, checked against the official AI literacy Q&A, each with its practical meaning.
Status as of October 13, 2026. The Commission's page was last updated on July 27, 2026. Not legal advice.
What the Commission's AI literacy Q&A is and what changed in July 2026
The Q&A is the Commission's running guidance on Article 4: not legally binding, but the clearest official word on how it reads the article.
The July 2026 update reflects the Digital Omnibus on AI (Regulation (EU) 2026/1744). Providers and deployers no longer have to ensure, "to their best extent, a sufficient level of AI literacy". They must take measures to support its development among their staff and others operating AI on their behalf, without guaranteeing any specific level for any individual.
The Commission and the Member States must support organizations, in particular SMEs, and the Commission is to publish practical examples of compliance. For the full comparison, see Article 4 after the Digital Omnibus.
Who is covered: answers 1–3
1. Does Article 4 still apply after the Digital Omnibus?
Yes. AI literacy has been an obligation for providers and deployers since February 2, 2025, and it remains one. Only the standard changed.
In practice: The softer wording does not remove the duty to act, and your existing training still counts.
2. Does it apply if staff only use ChatGPT to write or translate?
Yes. The Q&A uses this very example: a company whose employees use ChatGPT for advertising copy or translation must comply. Those employees "should be informed about the specific risks, for example hallucination."
In practice: A marketer drafting campaign text and a support agent translating a reply both need to know: confident doesn't mean correct.
3. Who counts as "staff and other persons"?
Staff are the people in your organization who deal with AI systems. "Other persons" are not employees but act broadly under your organizational remit, such as a contractor, a service provider or, depending on the risk, a client.
In practice: List the outsiders who use AI on your behalf: the agency writing your newsletter, a freelancer handling support tickets, temporary staff. They belong in your plan, even if someone else trains them.
What your program must cover: answers 4–6
4. What is the minimum content?
The Q&A lists four points:
- a general understanding of AI in your organization;
- whether you act as a provider or a deployer of AI;
- the risks of the AI systems you provide or use;
- measures that fit your staff's technical knowledge, experience, education and training, and the context of use, including legal and ethical aspects such as the AI Act itself.
In practice: Most companies deploy other people's tools, so focus on safe use, checking output and handling data.
5. Is training mandatory?
Not strictly. There is no one-size-fits-all approach and no mandatory training; guidance, workshops or mentoring can work too. But the Q&A warns that "relying on the AI systems' instructions for use or asking the staff to read them might be ineffective." Deployers of high-risk AI systems also have a duty under Article 26 to give human oversight to people with the necessary competence and training.
In practice: A link to the vendor's help pages is not a program; a short course plus your own AI policy is a common, proportionate mix.
6. Can different people get different levels of training?
Yes, the Q&A expects a risk-based approach. Staff with an AI degree or AI development experience can normally be considered AI literate, depending on the tool and their qualification, but check that they know your systems, your risks and the legal and ethical side. The AI Office sets no sector-specific requirements, though your sector shapes the risks.
In practice: An HR specialist screening CVs with AI needs more depth on bias and data protection than a field technician summarizing manuals. Plan by role.
Tip: The Aigen Campus course uses examples for 12 job roles in every module, and module 6 covers the AI Act and the learner's own responsibilities in plain language.
How to show what you did: answers 7–8
7. Do we have to test or measure employees' AI knowledge?
No. Per the Q&A, Article 4 "does not entail an obligation to measure the knowledge of AI of employees." You should still take their existing knowledge and experience into account.
In practice: A quiz or exam is optional, but shows whether the training worked.
8. Do we need a certificate or an AI officer?
No. "There is no need for a certificate," and the Q&A mandates no specific governance structure, such as an AI officer or an AI governance board. Organizations "can keep an internal record of trainings and/or other guiding initiatives."
In practice: Record who completed what and when, which version of your AI policy they acknowledged, and how often you refresh it. The AI literacy evidence guide has details.
Supervision and reach: answers 9–10
9. Who supervises Article 4, and from when?
National market surveillance authorities, not the EU AI Office. According to the Q&A, they began supervising and enforcing the rules in August 2026. Any penalties come from national law, and enforcement follows a proportionate approach.
Each country names its own authorities. In Finland, Traficom is the single point of contact under the Act on the supervision of certain AI systems (1377/2025), and Finnish law sets no penalty for breaching Article 4 (government bill HE 46/2025). In Sweden, no authority has yet been assigned Article 4.
In practice: The real reasons to act are fewer mistakes, less data in the wrong tools, and records for when a tender asks how your staff use AI.
10. Does Article 4 apply to companies outside the EU?
It can. The AI Act, Article 4 included, applies to actors inside and outside the EU when an AI system is placed on the EU market, used in the EU, or its use has an impact on people located in the EU.
In practice: A UK or US company serving EU clients should check its position: see does EU AI literacy apply to UK companies.
A one-page checklist based on the Q&A
| Question to ask | What the Q&A expects | Done? |
|---|---|---|
| Have we listed everyone who uses AI for us? | Staff plus contractors, service providers and, where relevant, clients | |
| Do people know the basics of AI and its limits? | General understanding, including risks like hallucination | |
| Do we know if we are a provider or a deployer? | Role shapes the content | |
| Have we mapped the risks of the tools we use? | Measures follow the risk | |
| Do measures differ by role? | Tailored to knowledge, experience and context | |
| Is there more than "read the manual"? | Instructions for use alone may be ineffective | |
| Do we cover rules and ethics? | Legal and ethical aspects, including the AI Act | |
| Do we keep a record? | Internal record of training and guidance; no certificate needed | |
| Do we refresh it? | Not required by the Q&A, but tools and rules keep changing |
If AI also changes how your staff work, check the employee consultation rules in the EU too.
Frequently asked questions
Is the Commission's AI literacy Q&A legally binding?
No. It is guidance from the Commission's AI Office; only the AI Act and national law bind you.
Where can I find examples of AI literacy programs?
The Commission keeps a living repository of AI literacy practices with more than 40 initiatives. Copying them does not automatically mean you comply, the Q&A notes.
Is there EU support for small companies?
Yes. The Q&A points SMEs to the European Digital Innovation Hubs, which offer AI services and can act as a first help desk on the AI Act. The amended Article 4 also obliges the Commission and Member States to support SMEs.
Does a certificate from a course prove compliance?
No. Article 4 requires no certificate. A course certificate is useful in your internal record, but it does not make an organization compliant on its own.
Get started
Aigen Campus gives your whole staff a 7-module AI literacy course of about 1 h 33 min, a final exam, verifiable certificates and an exportable competence register. The AI policy builder, publishing and acknowledgements are free. Create a free account and try module 1 with up to 5 users.