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AI Act eases staff literacy rules, but the duty remains

In brief

European regulation 2026/1744 of 8 July 2026 rewrote Article 4 of the AI Act. Companies no longer have to guarantee a specific level of AI literacy for each person, but must still foster the development of that literacy. According to the European Commission (FAQ updated 20 October 2026), the obligation remains for both providers and users of AI systems.

Source : Journal du Net - « L'Europe a allégé l'obligation de former à l'IA : ce n'est pas une raison pour s'en dispenser »

What it changes for an SME

You no longer have to guarantee a literacy level for each person, which eases a previously unclear requirement. According to the European Commission, you must still foster that literacy, including among contractors who use AI on your behalf. An internal record of training and related actions is enough; no certificate is required. National market surveillance authorities have been able to check this since 2 August 2026, and any sanctions must remain proportionate.

What you can do

  • Check that you keep an internal record of who received AI training, on which date and on which topics.
  • Include contractors and subcontractors who use AI on your behalf, as the Commission says they are covered.
  • Adapt the content to the real uses of each role rather than to one level for everyone.
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