An obligation that often goes unnoticed among SMEs is AI Act Article 4, dedicated to AI literacy. Unlike other obligations arriving in the coming years, this one has been in force since February 2025 and applies quite broadly to anyone using AI systems within their organisation.
What Article 4 requires
Article 4 requires organisations to ensure an adequate level of AI literacy among their staff and anyone operating AI systems on the organisation’s behalf. In practice: people who use AI at work need to understand, at a level appropriate to their role, how these tools work, what the main risks are, and how to use them responsibly.
This obligation applies broadly: it doesn’t just concern companies that develop AI, but also — and especially — SMEs that simply use AI tools in their day-to-day work.
Why documenting it matters, not just “doing” it
Many SMEs are probably already doing something in this direction, even informally: some guidance given to the team, a shared tutorial, a rough internal policy. The problem is that without documented evidence, it’s hard to demonstrate compliance with the obligation if questioned.
How to document it in 3 steps
Step 1 — Who uses AI and for what. Make a list of the people or roles using AI tools, broken down by area: management, sales/marketing, HR, IT/security, operations. This list is the foundation for everything else.
Step 2 — What training has been assigned. For each role area, define what type of AI literacy training is appropriate. Not everyone needs the same level of detail: someone using AI operationally needs different content than someone supervising or evaluating it from a security standpoint.
Step 3 — Keep completion evidence. Every time someone completes a training module, keep evidence: a completion record, a date, ideally a certificate. This is what makes the whole process demonstrable.
An important clarification
Completion records and certificates generated by our AI Literacy platform are evidence of training completion — they are not an official or legal certification. They’re a useful document to demonstrate diligence, not a credential recognised by a regulatory body.
How to get started
With the AI Literacy module you can assign role-based training paths and automatically generate completion records. If you’re not sure where to start, the Free Assessment helps you understand which areas of your organisation need training the most.
This article is for general information and is not legal advice.