Most companies think they are covered under the EU AI Act’s Article 4 literacy requirement because they published a policy document and ran a training session at some point. Inspectors starting their rounds in August are asking a different question. They want to know whether your people understand the risk level of the AI tools they use and whether they know when a decision needs to be escalated to someone else. A policy shows intent. A training certificate shows attendance. Neither shows that.

That gap was the subject of a live session we hosted on our landing page, where compliance lawyer Begoña Cendoya Iriondo joined our CEO Laura Fernández Giménez and Maida Gómez from our partnerships team to walk through what Article 4 actually requires and where most companies are getting it wrong.

What Article 4 actually asks

Article 4 draws a distinction between deployers and providers, and the obligations differ depending on which one your company is. It also asks for risk stratification across teams, since the AI risk profile of a legal department is not the same as a marketing team’s, and a single generic training session cannot cover both. The session broke down what documentation needs to look like to hold up under regulatory scrutiny, not just what needs to exist on paper.

Where standard training falls short

A lot of companies already ran an AI training session at some point in the last two years. The panel addressed head on why that session, however well intentioned, does not satisfy Article 4 on its own. The requirement is not that people sat through a course. It is that they can recognise risk and know what to do about it, which is a different bar and one that most existing programmes were never built to clear.

Who this was for

The session was built for compliance officers, AI leads, HR and L&D professionals, and the CHROs and Chief People Officers who ultimately own this risk at board level. If Article 4 sits on your desk in any of those roles, this is the session that maps out what inspectors will look for and what your existing programme is missing.

Watch the recording

The session ran live once and was only available through our landing page, so if you missed it, the recording is the only way to see it now. It also covers how Spanish companies can fund the training programme that closes this gap through FUNDAE at no net cost.