AI literacy: satisfying Article 4

Article 4 is the obligation people forget, and it is already in force — since 2 February 2025. It applies to every provider and deployer, whatever the risk tier of their systems: you must take measures that support the AI literacy of your staff and the other people dealing with the operation and use of your AI systems on your behalf.

What "sufficient" means

It is proportionate, not a fixed curriculum. The Act points to people's technical knowledge, experience, education and training, the context the system is used in, and the persons it is used on. A data scientist building a model and a caseworker using its output need very different things — but both need something, and so does the person answering the phone about it.

Where the work happens

AI Literacy (under Prove it) is the in-app Art. 4 screen, and it works per person:

1. Six questions about what you do — operate a system, review its decisions, handle the personal data it uses, take governance decisions about adopting it, and so on. Answer honestly rather than generously; the answers are filed against your account with the date.
2. Programmes are assigned automatically from the answers. Everyone gets the baseline, because Art. 4 binds the whole organisation; each yes adds the programme that competency needs.
3. Work through the programmes in the training player, and take the assessment where a programme has one.
4. Your record shows what is assigned, what is complete, and when it lapses — including any course your organisation asked you to take, under Assigned to you, with who asked, why and by when.

Org admins and compliance managers get a Team tab — who is current — listing who is complete, expiring or never started. They see standing, not answers. People whose role includes Assign training also get an Assignments tab: choose people and a course, add an optional due date and a reason, and each person is emailed a link to it. The due date is your organisation's own, never a legal deadline, so a missed one reads Past due date. The Org admin decides which roles hold it, in the role editor under Organisation → Members & roles; by default the Org admin, Compliance manager, Compliance officer and System owner roles do.

The record, and when it lapses

A completed record is valid for twelve months from completion: it lapses at midnight Irish time on the same date a year later. Once you have answered the six questions, a fortnight before it runs out you are told, by email and in the app; if it lapses you are told again. If you were assigned more than one programme, your record runs out when the first of them lapses; retaking a programme replaces its earlier completion. Your own standing also shows under Organisation → AI literacy.

A lapsed completion no longer counts towards Art. 4. Each system's Art. 4 obligation reads Done while at least one current completion is on file in the workspace, goes back to In progress when the last one lapses, and reads Done again after a new completion.

How it counts

The Art. 4 obligation on the organisation lives in the Scope & literacy stage of every system's journey, appears once on the Obligations register as an organisation row, and is satisfied once, for the workspace. The AI Literacy records are the evidence behind it: the dated needs assessment, the completions and the team view. Documents carries the AI Literacy Programme as an organisation-wide record of Kind Policy.

A completed programme is not a certification, and not a legal opinion that your organisation satisfies Art. 4. It is a dated record that the training happened and who did it. Whether it is sufficient for your particular use of AI remains your organisation's judgement.