Is AI Training Mandatory? What Article 4 of the EU AI Act Really Requires

"Do we now have to train our employees on AI?" Many companies have been asking themselves this question since early 2025. The short answer: the law requires sufficient AI competence among everyone who works with AI, not necessarily a specific course or a specific certificate. Training is the most practical way to build and demonstrate this competence.

What Article 4 of the EU AI Act requires

Under Article 4 of Regulation (EU) 2024/1689 (the "EU AI Act" or AI Regulation), providers and deployers of AI systems must promote the AI competence of their staff, and of the people who operate AI systems on their behalf. The obligation has applied directly since February 2, 2025 (source: EUR-Lex, Regulation (EU) 2024/1689, Art. 4; applicability under Art. 113).

Important: Article 4 applies regardless of the risk class of the AI system. Everyday use of tools like ChatGPT, Microsoft Copilot or Google Gemini also falls under it (source: BMDS, Federal Ministry for Digital Affairs and State Modernisation, Advisory Centre for Artificial Intelligence (BeKI), guidance on Art. 4).

What "AI competence" means legally

The term is defined in Art. 3(56) of the AI Regulation: it means "the skills, knowledge and understanding that allow providers, deployers and affected persons to make an informed deployment of AI systems, as well as to gain awareness about the opportunities and risks of AI and possible harm it can cause" (source: EUR-Lex, Regulation (EU) 2024/1689, Art. 3(56)).

Who does the obligation apply to?

• Deployers, in practice nearly every company that uses AI in daily work.
• Providers, who develop or supply AI systems.
• Commissioned service providers can also be covered, depending on the purpose of use (source: BMDS/BeKI).

"Sufficient" does not mean "expert level"

The BMDS makes it clear: the training is not held to expert level; what is required is "sufficient competence," the scope of which depends on the purpose of use, the complexity of the system, prior knowledge and the possible impact on fundamental rights. Anyone who already has relevant training or experience may already qualify as competent for a given tool. Simply reading a user manual, however, is generally not enough (source: BMDS/BeKI, "Content of the training").

What happens if the obligation is ignored?

A common misconception: "a fine of up to 35 million EUR applies if AI training is missing." That is not correct. The highest fine tier of the AI Regulation (up to 35 million EUR or 7% of worldwide annual turnover) applies to prohibited AI practices under Art. 5, not Article 4 (source: EUR-Lex, Regulation (EU) 2024/1689, Art. 99 in conjunction with Art. 5). Article 4 is not assigned its own fine tier in Art. 99. What is practically relevant instead are questions of liability and duty of care: if damage occurs that can be traced back to a lack of AI competence, this can have legal consequences (source: BMDS/BeKI, "Consequences of non-compliance").

How companies implement Article 4

• Offer an introductory training before the first use of an AI system.
• Refresh it regularly (for example, annually) and whenever systems or the legal situation change.
• Document who was trained on which content and when, for audits and your own compliance management (source: BMDS/BeKI, "Timing" and "Documentation and proof obligations").

A quick, practical way to get started is our AI competence certificate under Art. 4 of the EU AI Act: an online course with a final exam and a verifiable training record, in about 90 minutes per employee.

Sources

• Regulation (EU) 2024/1689 (AI Regulation / EU AI Act), EUR-Lex: eur-lex.europa.eu/eli/reg/2024/1689/oj
• European Commission, "AI literacy: Questions & Answers": digital-strategy.ec.europa.eu
• BMDS (Federal Ministry for Digital Affairs and State Modernisation) / Advisory Centre for Artificial Intelligence (BeKI): "Building AI competence under Art. 4 AI Act (AI Regulation), guidance for basic training" (Oct. 2025): bmds.bund.de

This article is general information and does not replace legal advice.