Until July 2026, Article 4 of the EU AI Act asked businesses to ensure a “sufficient level of AI literacy” among their people. Since 27 July, it says something else. The word “sufficient” has gone.
Anyone reading that will ask the obvious question: does this mean AI training for employees is no longer mandatory? The short answer is no. The longer answer covers what changed, who the rule applies to, what counts as a measure and what it costs.
Is AI literacy training for employees mandatory?
Yes, for every business that uses AI systems at work. Article 4 of the AI Act, Regulation (EU) 2024/1689, has applied since February 2025, and the July 2026 amendment did not remove it.
Strictly speaking, the law asks for measures rather than training. Training is the measure most businesses think of first, and usually the right one. It is not the only one. A clear rule on which data may go into which tool belongs to it as much as a named person people can ask.
Whether you build AI systems or use an off-the-shelf tool makes no difference to Article 4. Both roles are covered.
What the Omnibus changed
Regulation (EU) 2026/1744, the Digital Omnibus on AI, rewrote Article 4 with effect from 27 July 2026. Before, providers and deployers had to take measures to ensure, to their best extent, a sufficient level of AI literacy among their staff. Now they must take measures to support the development of AI literacy among their staff and other people working with AI systems on their behalf.
A new sentence was added as well. In substance it says the obligation does not require any individual to reach a specific level of AI literacy.
That sounds like relief, but it is really a shift. Nobody has to prove any more that every person on the team knows “enough”. What moves to the front is what you actually did. If you did nothing, you have not met the duty under the new wording either.
The yardstick the measures should follow has stayed in place: people’s technical knowledge, experience, education and training, the context in which the AI is used, and the people it is used on.
Who in your business is covered
A deployer is anyone using an AI system under their own authority in a professional capacity. That applies to many businesses. If someone in sales writes quotes with ChatGPT, accounts summarises receipts with an AI tool or a chatbot answers questions on your website, you are using AI.
The rule covers everyone working with it on your behalf. That means your own staff first, and by its wording also other people who operate AI systems for you, freelancers for example. Someone playing with a chatbot at home is not covered. Someone using it at work to answer customer mail is.
There is no size threshold. A trade business with eight people is as much a deployer as a corporation. The difference lies in scope: where AI only suggests text that a person reads, less is needed than where it makes decisions about customers.
What counts as a measure
The regulation does not prescribe a specific course. The European Commission’s questions and answers on Article 4 said before the amendment that no certificate is needed and that measures should fit how AI is used. A single online course for everyone with a certificate of attendance is therefore not automatically the best answer.
For a small or mid-sized business, four things usually belong together:
- A list of who uses which AI tool for what. Without it you do not know who needs training.
- Training on your own tasks. The person in sales practises with a real enquiry, accounts with a real receipt.
- Clear rules on which data may go into which tool and who checks AI output before it is sent.
- A short note of what you did, when and with whom. That is the part you can show if someone asks.
What good training has to achieve in daily work is the subject of our article After the AI workshop, can your team spot a wrong answer?. The core of it: after training, a person should notice when an AI draft makes a promise that no source supports.
Where your use sits within the regulation as a whole is covered on our EU AI Act overview. For a first assessment of your own case there is the EU AI Act checker. Neither replaces legal advice.
What AI training costs
AI training with Pharen starts at €499 per session, excluding VAT. The price depends on the length, the size of the group and whether we come to your premises. You get the exact figure in a quote after the intro call.
If you do not yet know which process AI is worth using for, the workshop from €399 excluding VAT is the better place to start. Afterwards you also know who needs training. All prices are on our services page.
There are options without Pharen too. In Saxony, the KI-Hub Sachsen-Thüringen and the Zukunftszentrum Sachsen are starting points for the fundamentals. That may be enough for a first overview. Practising on your own processes usually needs someone who gets to know those processes.
Is there funding for AI training?
Two schemes may apply to businesses in the Leipzig region, both with conditions.
The German government subsidises consulting for small and mid-sized businesses through the Federal Office for Economic Affairs and Export Control (BAFA). How much it covers depends on the region, and the guideline runs until 31 December 2026. The scheme is meant for consulting. Check with BAFA before you commission anything whether training qualifies.
The Saxon development bank SAB now accepts applications for its digitalisation grant only from businesses in the city of Leipzig, the district of Leipzig and Nordsachsen (as of October 2026). It applies from €5,000 of eligible costs, not to consulting alone, and you must apply before the project starts. A single training session at the starting price is well below that threshold. The grant becomes relevant when training is part of a larger digitalisation project.
For both, ask the funding body before you sign. With the SAB grant the application has to come before the start, so an early order can cost you the grant. How to sort consulting and funding in Saxony is covered in Do you need AI consulting, or a clearer first question?.
How we train at Pharen
Pharen is an AI consultancy from Naunhof near Leipzig. In our AI training your team practises on its own tasks. We clarify which tools your team may use and how, and we go through the rules for customer data, the GDPR and the EU AI Act.
Bring a typical case: an enquiry, a receipt or a customer email. We use it to practise what AI does well, where it goes wrong and who checks the result before it goes out.
If you then want to automate a process, we build it on your systems. Pharen Hub only comes in if something is missing. More on AI consulting in the region is on our AI consulting Leipzig page.
What is left of the word “sufficient”
The word has gone from Article 4, and with it the question of whether every person on the team knows enough. What remains is the question of what you did about it. A list, training on real tasks, clear rules and a short note answer it better than any certificate.
