The European Commission has published an official FAQ on AI literacy under Article 4 of the AI Act, providing the most detailed institutional guidance to date on the scope, enforcement, and practical application of the training obligation.
Key clarifications from the FAQ:
Article 4 is not limited to high-risk AI systems. The obligation applies to all providers and deployers of AI systems, including organisations using minimal-risk tools such as chatbots, content generators, and scheduling assistants. The obligation entered into force on February 2, 2025, meaning organisations should already be taking measures. However, supervision and enforcement by national market surveillance authorities begins August 2, 2026.
Enforcement sits with national market surveillance authorities, not the EU AI Office. The AI Office will coordinate with the AI Board to support consistent implementation across member states. Penalties for non-compliance with Article 4 fall under the general infringement tier: up to EUR 7.5 million or 1.5% of global annual turnover, whichever is higher (for SMEs and startups, whichever is lower).
Who it affects: Every organisation deploying or providing AI systems in the EU, regardless of sector or risk classification of the AI system in question.
What is notably missing: The FAQ does not define a minimum standard for what constitutes “sufficient AI literacy.” It does not specify training content, duration, or assessment requirements, leaving these to organisations’ own judgment within the proportionality framework. No centralised compliance guidance or template programme has been released.