Article 4 of the EU AI Act requires every organisation that uses AI to ensure its staff have a sufficient level of AI literacy — and it has been in force since 2 February 2025. It applies to any Irish business whose people use AI in their work, including ordinary tools like Copilot or ChatGPT, and the practical compliance question is simple: can you show what training your staff have had, and that it matches how they actually use AI?
What Article 4 actually says
The text (Article 4 of Regulation (EU) 2024/1689, on EUR-Lex) requires providers and deployers of AI systems to take measures to ensure, to their best extent, a sufficient level of AI literacy among staff and others using AI on their behalf — taking into account their technical knowledge, experience, education and training, and the context the AI is used in. Three things follow. It is an obligation on the organisation, not the individual. It scales with the role and the risk of the system. And “to their best extent” means the duty is to take real, proportionate measures — not to achieve perfection.
Why most Irish firms are missing it
Article 4 arrived quietly, in the same February 2025 tranche as the headline-grabbing prohibitions, and it has no dramatic trigger: no product launch, no procurement event, no deadline still to come. It simply applies, now, to every firm whose staff use AI. The Institute of Directors’ Q1 2026 finding that 65% of Irish directors don’t understand the new AI rules suggests the gap runs from the boardroom down. Many firms that would never miss a GDPR training cycle have no AI training records at all.
What “sufficient” looks like in practice
There is no prescribed curriculum, but a defensible programme is role-based. A reasonable structure for an Irish SME:
- All staff: what AI the firm permits, the basics of how it can be wrong (hallucination, bias), and what must never go into a public tool (personal data, confidential information).
- Staff using higher-stakes systems — recruitment, credit, customer decisions: how the specific tool works, its known limits, and when to override it.
- Owners and overseers: the firm’s AI Act obligations and the escalation route when something goes wrong.
- The board: enough understanding to ask the right questions — which is the heart of board oversight of AI.
How to evidence compliance
Evidence is the difference between having done the training and being able to prove it. Four records do the job:
- A short, written AI literacy plan describing who needs what level of training and why — your AI usage policy is the natural home for it.
- A dated training record per person: what they completed and when.
- A mapping from training to systems — staff using a high-stakes tool received the corresponding module.
- A refresh cycle, because tools and the rules both change.
Keep the literacy record where the systems live
Literacy records only make sense alongside the register of AI systems they relate to. AI Register Ireland tracks Article 4 as a live obligation against every system you record, with the literacy register kept beside the evidence. Plans start small — see pricing.