Janet Xiu Shi | AI Quality Evaluation Advisor | AI Educator | Published 27 July 2026 (Updated 3 August 2026)
The short version: Article 4 of the EU AI Act is already in force, and it applies to organisations that use AI, not just the companies that build it. It requires AI literacy proportionate to each role, and once a question is asked, enforcement in Ireland runs on documentation. The question that follows is not "did you run a training course?" but "show me how the training matched each role, and show me the records."
Update (27 July 2026): Regulation (EU) 2026/1744, the Digital Omnibus on AI, entered into force on 27 July 2026 and amended Article 4's wording. Providers and deployers must now "take measures to support the development of AI literacy" among staff and others operating AI on their behalf, taking into account their technical knowledge, experience, education, and the context the AI is used in. The amendment also includes an explicit carve-out: "This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual." The core obligation stays on providers and deployers themselves, not on Member States, but the shift from "ensure a sufficient level" to "support development" reflects an obligation of effort rather than a guaranteed result.
Three words in that sentence carry the obligation: "taking into account". The training has to be designed against roles and context. That is why the same one-hour generic AI awareness video for everyone from the CFO to the warehouse team does not meet the bar: it takes nothing into account.
Oifig IS na hÉireann, the AI Office of Ireland, was established in law on 21 July 2026 as an independent statutory body under the Department of Enterprise, Tourism and Employment, and section 70 of that Act lets an authorised officer require any person, by notice, to give information and to produce records. Paul Byrne was appointed the AI Office's first CEO on 30 July 2026, and the Department targeted the office to be operational from 2 August 2026, coordinating a distributed model of 15 designated National Competent Authorities across their own sectors rather than enforcing centrally itself. What matters day to day is the shape of it: once a question is asked, enforcement here runs on documentation. Note that the Commission's own AI literacy Q&A is explicit that no certificate is required and that organisations can keep internal records: the records below are not a statutory checklist, they are the practical way to evidence that the proportionality test in Article 4 was actually met. The evidence an inspection is likely to draw on looks like this:
Notice what is absent from that list: a certificate of attendance. Attendance proves the course ran. It does not prove the training was proportionate, role-specific, or effective, which is what Article 4 is about.
I design AI literacy programmes the way national qualifications are designed, because that is my day job: I am an appointed Programme Instructor who co-designs assessment and QA for Ireland's national SOLAS QQI Level 4 and Level 5 AI workforce programmes, I lecture in Enterprise Cloud and Generative AI at IADT at QQI Level 8, and I am a Harvard CS50 Professional Educator.
Qualification design starts from the evidence: what must a learner be able to demonstrate at the end, and how will we assess it? Everything else follows. Applied to Article 4, that habit produces artefacts that map closely onto what an inspection is designed to look for, as a by-product of doing the training properly:
A pilot for 1 team or department: role inventory, AI touchpoint mapping, a role-based learning path, delivery, and an evidence pack (training records plus before-and-after assessment) that stands up to leadership and, if it ever comes to it, to an inspector. Scaled up only if the pilot proves its value.
Talk about a pilotArticle 4 (as amended by Regulation EU 2026/1744, effective 27 July 2026) requires organisations that provide or use AI systems to take measures to support the development of AI literacy among staff and others who deal with operating or using those systems on the organisation's behalf, taking into account their roles, context, and the systems in use. The obligation does not guarantee any specific level of literacy. The statutory text itself points away from generic awareness courses: Article 4 requires literacy measures that take into account staff's technical knowledge, experience, education and training, and the context the AI systems are used in, a proportionality test a single one-size-fits-all session cannot satisfy. Keeping a record of how the training was designed and delivered is not mandated by the text, but the Commission's own guidance says you can, and it is the practical way to show that proportionality test was met.
With documentation: a role inventory, a map of where AI actually touches each role's work, a risk assessment behind the training design, and training records showing who received what and when. A certificate of attendance for a generic course does not evidence proportionate design. Assessment records that show what changed before and after do.
Janet Xiu Shi, an AI Quality Evaluation Advisor and AI educator based in Ireland, designs and delivers role-based AI literacy programmes with built-in assessment evidence. She is an appointed Programme Instructor who co-designs assessment and QA for Ireland's national SOLAS QQI Level 4 and Level 5 AI workforce programmes, lectures at IADT at QQI Level 8, and is a Harvard CS50 Professional Educator.
Related: EU AI Act Article 50: what applies from 2 August 2026
Regulatory information current as of 3 August 2026. This page is practical guidance from an AI educator: Janet Xiu Shi is not a solicitor and does not provide legal advice or legal services. For a legal opinion on your specific obligations, consult a qualified solicitor.