News & Updates
AI-generated “Anyone who doesn’t train their people in AI risks fines under the EU AI Act.” You can save yourself that sentence. AI literacy was never on the penalty list, and with the Digital Omnibus the requirement is even explicitly softened.
AI literacy matters. But it isn’t a hard legal obligation with the threat of penalties. Anyone who claims otherwise is spreading panic, not compliance.
What Article 4 requires, and what it doesn’t
Article 4 of the EU AI Act has addressed AI literacy since 2 February 2025. In the previous version, companies had to “make their best efforts to ensure” that their staff had a “sufficient level” of AI literacy. Even that wording was soft: best efforts, not a guarantee.
Above all, though, Article 4 was never backed by fines. The AI Act’s penalties in Article 99 attach to prohibited practices and to specific provider and deployer obligations, not to AI literacy. So there was never any basis for the claim that a lack of training automatically leads to fines.
What the Digital Omnibus changes
The Digital Omnibus turns the duty to ensure into a duty to promote. Instead of ensuring a certain level, companies will in future have to take measures to promote AI literacy. Nobody has to guarantee any more that every single person permanently reaches a defined level of knowledge.
The reason: the “sufficient level” was too vague and burdened small companies in particular with disproportionate effort and legal uncertainty. The recital states, in essence, that AI literacy should be a strategic priority, independent of regulatory obligations and possible sanctions.
This promotion model isn’t new. We’ve long known it from occupational safety, information security and data protection: raise awareness and inform, rather than certify every individual.
A note on the current status: Parliament adopted the reform on 16 June 2026; it isn’t yet in the EU Official Journal. Until publication, the old - and already soft - version formally applies.
No hard obligation doesn’t mean it doesn’t matter
“No fine” doesn’t lead to “ignore it.” AI literacy stays relevant in several places, just not as a penalty norm.
It’s part of due diligence. If improper AI use causes damage, such as a data leak or a decision based on invented figures, the question arises whether the company enabled its people. It’s part of human oversight: anyone operating high-risk AI must bring their staff far enough to actually exercise that oversight, and this requirement remains. And it’s simply good business sense.
What that means in practice
No panic, no certification requirement, no mandatory training program. What counts is that the people who work with AI understand the essentials: what the tool can do, where it invents content, which data may go in, when a human has to check the result.
This can be solved in a role-based way and with a sense of proportion. A note here, a short briefing there, a clear usage policy. For most, it doesn’t take more.
Why it’s still worth it
The real reason for AI literacy was never the law. Those who enable their people get fewer data mishaps, better results and employees who use AI instead of quietly bypassing it. That pays off, whatever the Official Journal says.
The prerequisite is that you know where AI is used in your company and who works with it. That’s exactly what the NADOVO platform makes visible. Where sensible awareness-raising starts is something we clarify in our AI compliance consulting. The fundamentals of the EU AI Act are covered in more depth in our article on what companies need to know now.
One question to close. Does anyone in your company use AI without knowing its limits? That’s not a fine risk, but an operational one. Where you stand is shown by our quick check.
About the author
Jochen Stier is a co-founder of NADOVO with over 20 years of experience in process management and IT service management. He helps German SMEs implement the requirements of the EU AI Act systematically and pragmatically. His 5-phase NADOVO framework combines regulatory requirements with practical feasibility, without enterprise budgets or complex tools.
Further reading:
- AI Literacy - Questions and Answers from the European Commission
- EU AI Act, Article 4 full text (EUR-Lex)