Skip to content

Knowledge base · AI in HR

Do we have to make our HR team AI literate if we use AI tools?

Yes. Since 2 February 2025, every organisation that uses AI systems professionally must take measures that support the AI literacy of its staff. Since 27 July 2026 a simplified text applies: you must support the development of AI literacy, but you do not have to guarantee a particular level.

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 the law now asks

You are a deployer as soon as you use an AI system under your own authority, for example a tool that sorts CVs or a language model that writes job ads [1]. As a deployer you take measures that support the development of AI literacy among your staff and others who work with AI systems on your behalf [2]. The duty does not mean that you must ensure a particular level [3].

Since when, and what changed

Article 4 is in Chapter I of the AI Act, and that chapter has applied since 2 February 2025 [4]. The original text asked to ensure, to their best extent, a sufficient level of AI literacy [5]. Regulation (EU) 2026/1744 replaced that text; it was published on 24 July 2026 [6] and entered into force on the third day after that [7], that is on 27 July 2026.

What that means for HR

Tailor the measures to who does what: a recruiter who reads candidates' AI scores needs different knowledge from an employee who has a chatbot write texts. The law names as benchmarks technical knowledge, experience, education and training, the context of use and the persons on whom the systems are used, such as applicants and employees [2]. The Commission and the Member States support SMEs in this, and the Commission publishes practical examples [8]. Record which measures you take, so that you can show them later.

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] AI Act Art. 3(4) (AI Act, Regulation (EU) 2024/1689). A deployer is anyone who uses an AI system under their own authority, except in the course of a personal non-professional activity.
    ‘deployer’ means a natural or legal person, public authority, agency or other body using an AI system under its authority except where the AI system is used in the course of a personal non-professional activity;
    Source, retrieved on 2 October 2026.
  2. [2] Regulation (EU) 2026/1744 Art. 1(5) (replaces AI Act Art. 4(1)) (Regulation (EU) 2026/1744 (Digital Omnibus on AI)). Providers and deployers of AI systems take measures that support the development of AI literacy among their staff and other persons operating and using AI systems on their behalf, tailored to knowledge, experience, training, context of use and the persons on whom the systems are used.
    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 2 October 2026.
  3. [3] 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 2 October 2026.
  4. [4] 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 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 2 October 2026.
  5. [5] AI Act Art. 4 (original text) (AI Act, Regulation (EU) 2024/1689). The original text asked for measures to ensure, to their best extent, a sufficient level of AI literacy.
    Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff
    Source, retrieved on 2 October 2026.
  6. [6] Regulation (EU) 2026/1744, OJ heading (Regulation (EU) 2026/1744 (Digital Omnibus on AI)). Regulation (EU) 2026/1744 was published in the Official Journal of 24 July 2026.
    L series 2026/1744 24.7.2026
    Source, retrieved on 2 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, that is on 27 July 2026.
    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 2 October 2026.
  8. [8] Regulation (EU) 2026/1744 Art. 1(5) (replaces AI Act Art. 4(2)) (Regulation (EU) 2026/1744 (Digital Omnibus on AI)). The Commission and the Member States support SMEs in particular with this duty; the Commission publishes practical examples.
    The Commission and the Member States shall support and facilitate the efforts of providers and deployers of AI systems, in particular SMEs, in fulfilling their obligation under paragraph 1 of this Article. For that purpose, the Commission shall publish practical examples of how to comply with that obligation on the single information platform referred to in Article 62(3), point (b).
    Source, retrieved on 2 October 2026.

Related questions

What do we, as an SME, have to arrange now if we use AI in HR?We are buying an AI tool for HR. Are we then the provider or the deployer?Do our employees need an AI literacy certificate or a mandatory course?

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

Looking for a specialist? We will look with you for a suitable specialist; mediation is not guaranteed.

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