EU AI Act Article 4 & Omnibus Law: What Businesses Must Know

The EU AI Act is Europe’s flagship regulation for artificial intelligence. Article 4 originally imposed a strict AI literacy requirement for Providers and deployers of AI systems to “ 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, taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in, and considering the persons or groups of persons on whom the AI systems are to be used”.

In summary, what Article 4 originally required:

• AI Literacy Obligation: Providers and deployers of AI systems must ensure that staff and anyone operating AI systems have sufficient knowledge about AI, including risks, safeguards, and context of use. This became enforceable on 2 February 2025.

Instead, the Omnibus Law Proposal as of 19 November 2025 changes this:

• AI literacy is no longer a mandatory obligation for providers and developers. Instead, the responsibility shifts to EU institutions and Member States to encourage them take these measures.

We’ll have to wait and see how these changes are approved and implemented in practice and what guidance follows from the EU. Stay tuned as we unpack the Omnibus Law in detail.

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