Does Article 4 of the EU AI Act apply to a UK business?
It can, even though the UK is outside the EU. Article 4 binds "providers" and "deployers" of AI systems. Article 3 defines them, and Article 2 sets out when the Act covers them if they are based outside the EU. Find the row that matches what your business does.
| What your business does | What the law says | Is Article 4 likely to cover it? |
|---|---|---|
| Sells or supplies an AI system in the EU under its own name | Article 2(1)(a): the Act applies to "providers placing on the market or putting into service AI systems or placing on the market general-purpose AI models in the Union, irrespective of whether those providers are established or located within the Union or in a third country". | Yes, as a provider |
| Supplies only a general-purpose AI model in the EU, not an AI system | Article 3(3) counts a business that places a general-purpose AI model on the market as a provider, but Article 4 names providers and deployers "of AI systems". The Act defines the two separately. Article 3(1): "‘AI system’ means a machine-based system that is designed to operate with varying levels of autonomy and that may exhibit adaptiveness after deployment, and that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments". Article 3(63): "‘general-purpose AI model’ means an AI model, including where such an AI model is trained with a large amount of data using self-supervision at scale, that displays significant generality and is capable of competently performing a wide range of distinct tasks regardless of the way the model is placed on the market and that can be integrated into a variety of downstream systems or applications, except AI models that are used for research, development or prototyping activities before they are placed on the market". | Not on that basis alone. It may if the business also provides or uses an AI system, for example one built on its own model: then check the other rows, and take advice if unsure. |
| Has an office, branch or company in the EU that uses AI systems | Article 2(1)(b): "deployers of AI systems that have their place of establishment or are located within the Union". | Yes, for the part in the EU, as a deployer |
| Provides or uses AI in the UK, and what the AI produces is used in the EU | Article 2(1)(c): "providers and deployers of AI systems that have their place of establishment or are located in a third country, where the output produced by the AI system is used in the Union". | Yes, as a provider or deployer. Recital 22 explains this point as applying "to the extent the output produced by those systems is intended to be used in the Union". |
| Uses AI only in the UK, and none of its output is used in the EU | None of points (a) to (c) describes this. | No, on the text of Article 2. The Commission also mentions AI whose use affects people in the EU (below): if that may be you, take advice. |
| A person using AI for purely personal, non-work reasons | Article 2(10): "This Regulation does not apply to obligations of deployers who are natural persons using AI systems in the course of a purely personal non-professional activity". | No |
The European Commission says, for firms outside the EU: "The AI Act’s legal framework applies to both public and private actors inside and outside the EU as long as the AI system is placed on the Union market, used in the Union or its use has an impact on people located in the EU. This is also valid for Article 4 of the AI Act." Its wording is wider than Article 2, as it adds AI whose use has an impact on people in the EU.
The UK government's memorandum to Parliament, from the Department for Science, Innovation and Technology, says: "For UK businesses (including those in Northern Ireland) trading into the EU single market, the AIA’s broader requirements will apply to AI systems placed on the market or put into service in the EU regardless of domestic UK regulation." It is narrower than Article 2, as it doesn't mention AI output used in the EU.
The table maps the law's own words to common situations. It is not legal advice: if you can't tell which row fits, ask a qualified adviser.
When does the AI literacy rule apply?
It has applied since 2 February 2025, and the amended wording took effect on 27 July 2026. These are the dates from EUR-Lex and the Commission, side by side.
| Date | What happened | Official wording |
|---|---|---|
| Article 4 starts to apply (it sits in Chapter I of the Act) | Regulation (EU) 2024/1689, Article 113: "Chapters I and II shall apply from 2 February 2025". EUR-Lex | |
| Regulation (EU) 2026/1744, the Digital Omnibus on AI, signed on 8 July 2026, is published in the Official Journal | Official Journal heading: "L series 2026/1744 24.7.2026". EUR-Lex | |
| The amendment takes effect and replaces the text of Article 4 | EUR-Lex: "Date of effect: 27/07/2026". Article 113(a) as amended keeps 2 February 2025 for Chapters I and II. EUR-Lex | |
| National authorities in EU countries start supervising and enforcing Article 4 | Commission: "The national market surveillance authorities will start supervising and enforcing the rules as of 2 August 2026". Commission Q&A |
Enforcement sits with each EU country, not with Brussels. The Commission says: "The supervision and enforcement of Article 4 of the AI Act is not with the AI Office, but it is under the remit of national market surveillance authorities".
What does Article 4 require now?
Measures to support your staff's AI literacy, with no set level to reach. Regulation (EU) 2026/1744 replaced the whole article. Here is the old and the new wording in full, as published on EUR-Lex.
| Point | Original (from 2 February 2025) | As amended (from 27 July 2026) |
|---|---|---|
| The duty | "Providers and deployers of AI systems shall 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" | Article 4(1): "Providers and deployers of AI systems shall take measures to support the development 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" |
| Level of AI literacy | "a sufficient level", "to their best extent" | "This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual" |
| Help for firms | Not in Article 4 | Article 4(2): "The Commission and the Member States shall support and facilitate the efforts of providers and deployers of AI systems, in particular SMEs, in fulfilling their obligation under paragraph 1 of this Article. For that purpose, the Commission shall publish practical examples of how to comply with that obligation on the single information platform referred to in Article 62(3), point (b)." |
| Recommendations | Not in Article 4 | Article 4(3): "The Board shall adopt recommendations, taking into account European competence frameworks, to support the Commission and Member States in the promotion of AI literacy required under paragraph 1, including by setting out common objectives." |
So the duty to act stays, but you no longer have to reach "a sufficient level". No date for the AI Board's recommendations under Article 4(3) is stated on EUR-Lex or the Commission's pages. Article 3(56) defines AI literacy: "‘AI literacy’ means skills, knowledge and understanding that allow providers, deployers and affected persons, taking into account their respective rights and obligations in the context of this Regulation, to make an informed deployment of AI systems, as well as to gain awareness about the opportunities and risks of AI and possible harm it can cause".
"Staff and other persons" reaches past your payroll. The Commission gives examples of the other persons: "It could be, for example, a contractor, a service provider, a client".
If you use high-risk AI systems, a separate duty comes later. Article 26(2), in Chapter III, Section 3, says: "Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support." Article 113(c), as amended by Regulation (EU) 2026/1744, says: "Chapter III, Sections 1, 2, and 3, with the exception of Article 6(5), shall apply from: (i) 2 December 2027 as regards AI systems classified as high-risk pursuant to Article 6(2) and Annex III; and (ii) 2 August 2028 as regards AI systems classified as high-risk pursuant to Article 6(1) and Annex I". So that duty applies from 2 December 2027 for Annex III high-risk systems and from 2 August 2028 for Annex I systems. The Commission notes that "for those who deploy high-risk AI systems, the obligation to ensure that their staff is trained to ensure human oversight remains in place".
Do you need a certificate or a set course?
No. The Commission's AI literacy Q&A says: "There is no need for a certificate. Organisations can keep an internal record of trainings and/or other guiding initiatives." It also says: "There is no one size fit all when it comes to AI literacy and no strict requirements or mandatory trainings are imposed." And it adds: "Article 4 of the AI Act does not entail an obligation to measure the knowledge of AI of employees."
What AI literacy training helps?
Training that fits the AI your staff use and the risks it carries. The Commission says providers and deployers "should consider at least the following steps and questions", quoted from its Q&A:
- "Ensure a general understanding of AI within their organisation: What is AI? How does it work? What AI is used in our organisation? What are its opportunities and dangers?"
- "Consider the role of their organisation (provider or deployer of AI systems): Is my organisation developing AI systems or just using AI systems developed by another organisation?"
- "Consider the risk of the AI systems provided or deployed: What do employees need to know when dealing with such AI system? What are the risks they need to be aware of and do they need to be aware of mitigation?"
- "Concretely build their AI literacy actions on the preceding analysis", taking into account staff's knowledge and the context the AI is used in.
It warns that "in many cases, simply relying on the AI systems’ instructions for use or asking the staff to read them might be ineffective". On staff who use ChatGPT to write or translate text, it answers: "Yes, they should be informed about the specific risks, for example hallucination".
Which courses on this site cover the EU AI Act?
These are the courses we list that teach the EU AI Act itself, with facts from each provider's own page. None is required by Article 4; check whether a course covers the July 2026 changes before you book.| Course | Provider | Cost | Time | Certificate |
|---|---|---|---|---|
| Secure AI Adoption for SMEs: Cybersecurity and the EU AI Act | CyberSuite Academy | Free | About 15 h | Free certificate |
| Introduction to Artificial Intelligence for Public Service Interoperability | EU Academy | Free | Duration not stated | Free certificate |
| Advanced Programme on AI Law and Policy | University of Oxford Faculty of Law | £3,600 plus accommodation (£350) | About 16 h | Certificate included in fee |
These steps are for your organisation to work through, especially step c) on the risks of the AI systems your business provides or uses. No course does that for you.
For a general first grounding for staff, these free courses cover AI literacy topics, such as using AI at work and its risks. They don't replace your own review of the AI systems your business uses.| Course | Provider | Cost | Time | Certificate |
|---|---|---|---|---|
| Work smarter with AI | Microsoft | Free | Under 1 h | Free badge |
| AI Foundations | OpenAI | Free | About 1 h | Free badge |
| AI Fluency for Small Businesses | Anthropic | Free | About 3.5 h | Free badge |
| AI Fluency: Framework & Foundations | Anthropic | Free | About 4 h | Free badge |
Every adult in the UK can also take the free AI Skills Boost courses. For more options, see free AI courses in the UK.
Does the UK have its own AI Act?
No single law. GOV.UK's Introduction to AI assurance, published on 12 February 2024 and still live on 7 Nov 2026, says: "While there is not currently statutory AI regulation in the UK, there are existing regulations that are relevant for AI systems." It goes on: "For example, systems must adhere to existing regulation such as UK GDPR, the Equality Act 2010 and other industry-specific regulation."
So the AI literacy rule reaches UK businesses only through the EU AI Act's own scope, in the cases in the table above.
Does the EU AI Act apply in Northern Ireland?
Only in a few limited parts so far. The government's memorandum of 30 January 2026 says "[...] beyond limited provisions which amend existing EU law in Annex II of the Windsor Framework under Article 13(3), the EU AI Act does not apply under the Windsor Framework." It names those parts: "The limited provisions of the AIA currently applicable in Northern Ireland under Article 13(3) (Articles 103-107 and 109)". It adds: "The EU and UK are undertaking technical engagement on this issue and no decision has been made."
Check GOV.UK for any later decision. A Northern Ireland firm that trades into the EU is in the same position as the rest of the UK.
Where can you read the law?
- Regulation (EU) 2024/1689, the AI Act, on EUR-Lex: Article 2 (scope), Article 3 (definitions), Article 4 (AI literacy) and Article 113 (dates).
- Regulation (EU) 2026/1744, the Digital Omnibus on AI, on EUR-Lex: the new Article 4 is in Article 1, point (5).
- The European Commission's AI literacy Q&A, last updated 20 October 2026.
How we checked: we read each page above on 7 Nov 2026 and quote it word for word. We don't give legal advice.