AI literacy (Article 4 of the AI Act): the training obligation that opens a new market for training organisations

A European regulation that entered into force in 2024, a training obligation that has applied since February 2025, and an enforcement deadline set for 2 August 2026: AI literacy is not a forward-looking topic — it is a legal obligation already in force for every company that uses an artificial intelligence tool, and a training theme in growing demand. For a training organisation (OF), this is both a compliance question if you use AI internally yourself, and a genuine commercial opportunity: your client companies have an obligation to meet, and few of them know where to start.

What Article 4 of the AI Act actually says

Regulation (EU) 2024/1689 on artificial intelligence, known as the AI Act, requires under its Article 4 that every provider and every deployer of an AI system take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf. This requirement applies with no threshold for headcount or sector of activity: a five-employee company drafting its quotes with a generative AI assistant is covered exactly like a large group deploying high-risk AI systems.

The text does not lock in a mandatory curriculum. It requires taking into account the technical knowledge, experience, education and training of the people concerned, as well as the context in which the AI is used and the persons or groups of persons on whom the AI systems are to be used. In practice, a salesperson using a chatbot to draft emails does not need the same level of awareness as an HR department that would use a résumé-screening tool. It is precisely this lack of a rigid framework that makes support from a training professional so useful: turning a vague regulatory requirement into a concrete, documented programme.

2 August 2026: what really changes

The AI literacy obligation is not new — it has applied since 2 February 2025, from the entry into application of the regulation’s first provisions (bans on certain practices and general obligations). What changes on 2 August 2026 is the entry into application of most of the remaining framework, notably the rules on high-risk AI systems and the effective rollout of enforcement governance. In France, market surveillance relies on several authorities already competent in their own field rather than on a single authority created for the occasion, with a coordinating role given to the DGCCRF and jurisdiction for the CNIL over uses touching personal data. Many companies are discovering the AI literacy obligation at this point, even though it has already applied to them for a year and a half.

For a training organisation, this timeline has an immediate practical consequence: demand for AI awareness training in companies, previously scattered, is becoming structured and accelerating as legal and HR departments become aware of the issue. This is the moment to build an offer, rather than discover the need after the fact.

Building an AI literacy offer that holds up in a Qualiopi audit

Nothing stops a certified training organisation from offering an AI literacy course like any other subject in its catalogue. But as with any new course, it must meet the same requirements as the rest of your catalogue.

Analyse the need before copying a generic programme

A one-size-fits-all AI literacy course has little value for a client, and little value in an audit. Indicator 4 of the French National Quality Standard expects a needs analysis that distinguishes, for instance, a company using AI for sales copywriting from one using it to screen CVs or score customer files — two contexts that call for neither the same risks nor the same teaching content. Our article on analysing the training need covers the method and the expected evidence.

Set operational objectives, not just “awareness”

“Raising awareness of AI” is not an observable objective. Indicator 5 requires objectives phrased as assessable capabilities: identifying the risks of a given use, applying a procedure to check AI-generated content, recognising a high-risk use case under the regulation. Our guide to writing learning objectives applies here just as it does to any other topic.

Assess the actual level of participants before starting

The European text explicitly requires taking into account the technical knowledge and experience of the people being trained. That is exactly what Indicator 8 requires for entry-level assessment: a short test, even a simple one, lets you adjust the content between participants who have never used generative AI and others who already use it daily without knowing its limits. See our article on entry-level assessment.

Document your own monitoring, not just the content you sell

AI law is moving fast: emerging case law, delegated acts from the European Commission, and French authorities’ doctrine still taking shape. Keeping documented monitoring of these developments falls under the same discipline expected for Indicators 23 to 25 of the standard, and provides useful audit evidence as well as a mark of seriousness for your clients.

Separating your own compliance from the offer you sell

There are two related but distinct issues here. The first concerns your own organisation: if your teams use generative AI internally, your structure is itself a deployer under Article 4, with its own awareness obligation — a point our article on generative AI in a training organisation covers in detail, including its GDPR implications. The second concerns the commercial offer: designing and selling an AI literacy course for client companies, which means treating the subject like any new specialty added to your catalogue — and, where relevant, reporting it through an amended activity declaration if your initial declaration did not cover this scope.

On funding, stay cautious in your marketing: an AI literacy course may fall within a company’s skills development plan and be eligible for OPCO funding on the same basis as other courses, but each operator applies its own criteria — see our overview of OPCO funding before advertising unverified funding eligibility.

What research says about AI literacy

The concept of AI literacy did not appear with the European regulation: it has been studied for several years in education science and human-computer interaction research. A landmark study by Long and Magerko, presented in 2020 at the CHI conference (ACM Conference on Human Factors in Computing Systems) and awarded a Best Paper Honorable Mention, offers a synthesis of the competencies that make up AI literacy, based on an interdisciplinary review of the literature (see the study). The authors distinguish competencies of understanding (what AI can do, how it makes decisions), competencies of critical use, and ethical competencies — a framework that maps almost point for point onto the expectations of Article 4 of the European regulation, published several years after this study. For a training organisation building a programme, relying on these recognised categories rather than improvising gives the offer a solid pedagogical foundation, beyond mere regulatory compliance.

Quick checklist

• Does the needs analysis distinguish participants’ actual AI uses (writing, screening, decision support)?
• Are the learning objectives phrased as observable capabilities, not just “awareness”?
• Does an entry-level assessment let you adjust content to participants’ actual level?
• Does your own organisation document its own AI literacy if it uses AI internally?
• Is monitoring of the regulation’s evolution and French doctrine tracked and dated?
• Has any OPCO funding eligibility claimed in your marketing been verified with the operator concerned?

Take action

Building a solid AI literacy training offer requires the same rigour as any other course in your catalogue: needs analysis, measurable objectives, entry-level assessment and documented evidence. The Complete Kit Certif provides templates and evidence models for Indicators 4, 5 and 8 to build this new offer on solid ground, ready for your next Qualiopi audit. Launching your training organisation? The ebook Create Your Training Organisation in 30 Days lays the administrative foundations, and the complete pack brings both resources together.