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Obligations for Companies
AI Competence Under Art. 4:
What the New Obligation Means for You
The AI Act demands more than just technology. Article 4 establishes an overarching obligation for competence fulfillment. We explain what this means for your company and what strategic measures you need to take now.
Article 4 in Plain Language: The Core Requirements
Article 4 of the EU AI Act obliges providers and deployers of AI systems to take measures for adequate AI competence (AI Literacy) in the company. This applies to all employees who use or monitor AI systems on behalf of the company.
- Who is affected? Virtually every company that uses or offers AI.
- What needs to be done? Demonstrable "measures" are required, considering role, prior knowledge, and context.
In summary: Article 4 requires that your employees receive context-specific training and that this is documented traceably.
Why a Role-Based Approach is Crucial
A "one-size-fits-all" training would not only be ineffective but also miss the regulation's requirement for context-specific competence. Knowledge requirements differ fundamentally depending on responsibility in the company:
- Management Level: Needs strategic knowledge about risks, governance, and liability.
- Departments (Operational): Must know the limits of the AI tools they use and the correct reporting channels for incidents.
- IT/Engineering: Focuses on technical operations, monitoring, and data quality.
- Legal/Compliance: Must master legal definitions, obligations, and interfaces to GDPR.
A successful concept must satisfy these different needs and be mapped in a single framework.
Your Key Action Areas
To strategically meet the requirements of Article 4, companies must tackle several core areas. The following action areas form the foundation for compliant AI competence management:
- 1.Inventory & Role Clarification: Identify all AI systems in use and clearly define internal responsibilities (e.g., operational users, technical operators, strategic decision-makers).
- 2.Needs Analysis & Concept Development: Derive specific training needs from roles and risk levels of AI systems in use and develop an overall didactic concept.
- 3.Implementation & Integration: Conduct training measures and firmly anchor them in company processes, especially in onboarding for new employees.
- 4.Documentation & Review: Establish a lean process to comprehensively document the implementation and effectiveness of training and review regularly.
The Importance of Complete Documentation
Traceable documentation is not an end in itself, but crucial for demonstrating compliance with Article 4 obligations and minimizing liability risks. Audit-proof evidence typically includes:
- The Training Concept: Documentation of *what* content *who* learns at *what* frequency.
- The Implementation: Evidence of participation in respective training modules (e.g., attendance lists).
- The Effectiveness: Evidence that learning objectives were achieved (e.g., through use-case check protocols or "lessons learned").
- Process Integration: References in relevant work instructions (SOPs) that refer to the competencies learned.
Read Also
AI Act: Who is Obligated? Providers, Users & Co.
Understand the central roles (provider, user, importer) and the associated obligations under the EU AI regulation.
Read articleThe 4 Risk Classes of the AI Act Simply Explained
The heart of the AI Act is the classification into risk classes. Understand the logic from prohibited AI to high-risk systems.
Read articleFrequently Asked Questions (FAQ)
Is a knowledge test mandatory for employees?
No. Article 4 requires "measures" without mandating formal knowledge testing. However, a lean, documented effectiveness check is recommended to demonstrate implementation.
Does the AI competence obligation apply even without using high-risk AI?
Yes, Article 4 applies in a role- and context-specific manner to all providers and deployers of AI systems. For high-risk systems, documentation requirements within the quality management system (QMS) are more extensive.
How often must we train?
The law does not prescribe a fixed frequency. Annual refreshers have become best practice, supplemented by onboarding training and event-driven training when introducing new AI systems.
Legal Notice
This article is for general information purposes and does not constitute legal advice. It translates the requirements of Art. 4 AI Act into practical recommendations.