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Free guide · updated October 2026

EU AI Act Article 4 checklist: what your SME actually needs to do

Article 4 of the AI Act asks you to take measures so your staff understand the AI they use. No certificate is needed. This guide explains what it requires after Regulation (EU) 2026/1744 and how to handle it in 6 steps.

✓ Based on the European Commission FAQ✓ Covers Regulation (EU) 2026/1744✓ 8 min read

What Article 4 requires today

Article 4 of the EU AI Act has applied since 2 February 2025 to two kinds of organisation: providers, who develop or place AI systems on the market, and deployers, who use AI systems in their professional activity. An SME whose staff use ChatGPT, Copilot, Gemini or a CRM with AI features is a deployer.

Regulation (EU) 2026/1744, in force since 27 July 2026, reworded the article. The obligation is now to take measures to support the AI literacy of staff and other people using AI on the organisation's behalf, taking into account their technical knowledge, experience, education and training and the context the AI is used in. You no longer have to guarantee a specific level for each person, but the obligation still exists. National market surveillance authorities have supervised it since August 2026.

In one sentence: do something reasonable and proportionate so your team understands the AI it uses, and be able to show what you did.

What it does not require

The Commission does say that simply pointing staff to a tool's instructions for use is often not enough. Its example is clear: if your staff use ChatGPT to write or translate, they should know about specific risks such as hallucination.

The Article 4 checklist in 6 steps

This is the web version of our free checklist. You can also tick it off in the free online register. For an SME with 10 to 50 people, it can be done in an afternoon.

1Build an inventory of AI tools

  • List every AI tool in use: assistants such as ChatGPT, Copilot or Gemini, and AI features inside software you already pay for (CRM, email, translation, customer support).
  • Note who uses each tool, what for and with which data.
  • Include contractors or suppliers who use AI on your behalf: the FAQ counts them as “other persons”.

Use the register template (CSV) or the free online register: one row per tool. Unofficial use is usually bigger than expected, so ask each team.

2Work out your role and risk level

  • Do you only use AI (deployer) or do you also build or sell it (provider)?
  • Could any use be high-risk under Annex III, such as recruitment, worker evaluation or credit scoring? Then further obligations apply (for example, Article 26 requires human oversight by people with the necessary competence and training). Get professional advice.
  • Could any use be a prohibited practice under Article 5? Stop it.

3Plan measures by role

According to the FAQ, the minimum content to consider includes:

  • General understanding: what AI is, how it works, which AI the company uses, its opportunities and dangers.
  • The risks of each tool: hallucination, personal and confidential data, bias, intellectual property.
  • Tailoring by role: management, HR, sales and marketing, customer support, technical teams.
  • Basic legal and ethical aspects: the AI Act and the GDPR.

A short session per role, built around a real example from your work, usually lands better than one long generic course.

4Write an AI acceptable-use policy

  • Approved tools and who may use them.
  • What must never go into unapproved tools (personal data, client data, contracts).
  • Human review of anything sent externally or used in decisions about people.
  • An internal contact for questions and new tools.

One page is enough. What matters is that staff read it and that you record it.

5Keep a record of what you do

This is the step most often skipped, and the one that lets you show you acted. A simple internal record can have these columns:

FieldExample
Person and roleLaura M. · Sales
Date20 Oct 2026
ContentAI in sales: client data and reviewing proposals
Duration and format45 min · internal session + short quiz
Policy readVersion 1.0 · acknowledged 20 Oct 2026

6Review regularly

  • Update the inventory and training when you add a tool or change how one is used.
  • Do a general review, for example every six months.
  • Include AI literacy in onboarding for new starters.

Common mistakes

Free public resources

Sources

General information, updated 18 October 2026. Not legal advice.

Frequently asked questions

Is an AI literacy certificate mandatory?

No. The European Commission FAQ says no certificate is needed; an internal record of trainings and other measures is enough.

Does it apply if my team only uses ChatGPT?

Yes. Using ChatGPT at work makes you a deployer. The Commission uses this example: staff should know about risks such as hallucination.

What changed with Regulation (EU) 2026/1744?

Article 4 now requires taking measures to support AI literacy, without guaranteeing a specific level for each person. The obligation still exists and national authorities have supervised it since August 2026.

How long does it take?

For an SME, the inventory, the policy and a short session per role can be done in a few hours. What matters is that it fits your use of AI and is recorded.

Handle Article 4 in an afternoon

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