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Knowledge base · AI in HR

Do our employees need an AI literacy certificate or a mandatory course?

No. The AI Act does not prescribe a certificate, an exam or a fixed course. You take measures that support the development of AI literacy of your staff, tailored to who uses which AI systems; you do not have to guarantee a particular level. Training can be such a measure, but you choose the form yourself.

In force now (since 2 February 2025)Trusq editorial · checked against the official textLast verified:

Next step: Record your HR AI tools in Trusq

What Article 4 asks

As a deployer you take measures that support the development of AI literacy among your staff and others who use AI systems on your behalf, tailored to their knowledge, experience and training, the context and the people on whom the systems are used [1]. The duty does not mean that you must ensure a particular level [2]. A certificate, an exam or a mandatory course is not in the text.

Why the legislator does not prescribe a level

According to the recitals of the amendment, stakeholders' experience showed that strict obligations to ensure a sufficient level are not suitable for all organisations [3]. The Commission and the Member States must support organisations, including with training opportunities and information resources [4].

What does help

The knowledge needed differs per context: from the measures to be applied during use to how the output is to be interpreted [5]. A recruiter who reads AI scores therefore needs something different from a colleague who uses a chatbot to write texts. Record per role what you do, for example a short instruction, working agreements or a training course, so that you can show it later.

Since when

Article 4 is in Chapter I, which has applied since 2 February 2025 [6]. The current text comes from Regulation (EU) 2026/1744, which entered into force on the third day after its publication [7], that is on 27 July 2026.

What Trusq bases this on

These released rules are in Trusq and are read again with every publication; if a rule changes, this page changes with it.

  • Literacy programme AI Act 4
  • Role-based knowledge AI Act 4

Sources

  1. [1] Regulation (EU) 2026/1744 Art. 1(5) (replaces AI Act Art. 4(1)) (Regulation (EU) 2026/1744 (Digital Omnibus on AI)). Deployers take measures that support the development of AI literacy, tailored to knowledge, context and the persons concerned.
    Providers and deployers of AI systems shall take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be used.
    Source, retrieved on 3 October 2026.
  2. [2] Regulation (EU) 2026/1744 Art. 1(5) (replaces AI Act Art. 4(1), second sentence) (Regulation (EU) 2026/1744 (Digital Omnibus on AI)). The duty does not mean that a particular level of AI literacy must be ensured.
    This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual.
    Source, retrieved on 3 October 2026.
  3. [3] Regulation (EU) 2026/1744, recital 8 (Regulation (EU) 2026/1744 (Digital Omnibus on AI)). Strict obligations to ensure a sufficient level proved not to be suitable for all providers and deployers.
    However, experience shared by stakeholders reveals that a solution imposing stringent obligations to ensure a sufficient level of AI literacy would not be suitable for all types of providers and deployers in relation to the promotion of AI literacy.
    Source, retrieved on 3 October 2026.
  4. [4] Regulation (EU) 2026/1744, recital 8 (Regulation (EU) 2026/1744 (Digital Omnibus on AI)). The Commission and the Member States support, among other things, with training opportunities and information resources.
    The Commission and Member States should support and facilitate the efforts of providers and deployers of AI systems, including through offering training opportunities, providing informational resources, and allowing exchange of good practices and other initiatives.
    Source, retrieved on 3 October 2026.
  5. [5] AI Act, recital 20 (AI Act, Regulation (EU) 2024/1689). The knowledge needed differs according to context, up to the interpretation of the output.
    Those notions may vary with regard to the relevant context and can include understanding the correct application of technical elements during the AI system’s development phase, the measures to be applied during its use, the suitable ways in which to interpret the AI system’s output,
    Source, retrieved on 3 October 2026.
  6. [6] Regulation (EU) 2026/1744 Art. 1(40)(a) (replaces AI Act Art. 113, third paragraph, point (a)) (Regulation (EU) 2026/1744 (Digital Omnibus on AI)). Chapters I and II of the AI Act (including the definitions, Article 4 and the prohibitions of Article 5) have applied since 2 February 2025.
    Chapters I and II shall apply from 2 February 2025, with the exception of Article 5(1), first subparagraph, points (ba) and (bb), and Article 5(1a) and (1b) which shall apply from 2 December 2026;
    Source, retrieved on 3 October 2026.
  7. [7] Regulation (EU) 2026/1744 Art. 4 (Regulation (EU) 2026/1744 (Digital Omnibus on AI)). Regulation (EU) 2026/1744 enters into force on the third day after its publication.
    This Regulation shall enter into force on the third day following that of its publication in the Official Journal of the European Union.
    Source, retrieved on 3 October 2026.

Related questions

Do we have to make our HR team AI literate if we use AI tools?What does human oversight of a high-risk AI system for HR mean in practice?What do we, as an SME, have to arrange now if we use AI in HR?

Next step

Register the AI tools you use in HR. Trusq shows per tool which duties may apply and sets them up as actions, with the evidence that is expected and the source.

Record your HR AI tools in Trusq

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This page gives general information based on the text of the law. It is not legal advice for your situation.