Service
AI literacy under the AI Act: training for SMEs in Tyrol
If your business uses AI tools, you have had to take measures since February 2025 to help your people build the skills to use them. We turn that into something concrete: clear rules, training for your team and documentation that shows what was done.
What Article 4 requires
Article 4 of the AI Act (Regulation (EU) 2024/1689) has applied since 2 February 2025. It requires providers and deployers of AI systems to take measures on the AI literacy of their staff. A deployer is anyone who uses an AI system under their own authority, except for purely personal use, which includes a business that uses AI tools day to day.
Since the amendment by Regulation (EU) 2026/1744, in force since 27 July 2026, it reads: providers and deployers take measures to support the development of the AI literacy of their staff and other persons. A specific level for each individual does not have to be guaranteed. The obligation itself remains.
It also covers people who work with AI on the business's behalf. How much is needed depends on prior knowledge, the context of use and the persons affected; the RTR AI service desk also names the risk level.
What Article 4 does not require
- No certificate
- The regulation prescribes neither minimum content nor a specific certificate.
- No separate fine range
- The regulation itself sets no fine range for Article 4 (Art. 99(3) to (5)); member states lay down penalties nationally (Art. 99(1)). The AI service desk of the Austrian RTR also points out that missing training can matter under civil law if damage occurs (§ 1313a ABGB).
- No one-size programme
- Not everyone needs the same training. Someone who only uses AI to draft text needs something different from someone who processes customer data with it.
How we implement it
- Inventory
- Which AI tools are actually used in the business, by whom and for what.
- Rules
- A short internal AI policy: what is allowed, which data does not belong in AI tools, who approves.
- Training
- Practical for your team, based on your own processes rather than generic examples.
- Documentation
- Who was trained on which tools and rules, and when. This matches the recommendation of the RTR AI service desk to document implementation so it can be demonstrated.
- Scope
- Legal assessments, for example on data protection and liability, are made by a lawyer. We create the organisational rules and the training.
Data protection is part of it
AI literacy also means knowing which data may go into an AI tool. From our practice, we recommend not entering personal data, and health data in particular, into freely available AI services. Whether and under which conditions this is permissible under data protection law is a question for legal advice.
Status and sources
Status: 21 October 2026. Basis: Articles 4 and 99 of Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744, and the information of the RTR AI service desk (rtr.at). This page is practical guidance and not legal advice.
Frequently asked questions
Questions about AI literacy
Does the obligation apply to small businesses too?
Yes. Article 4 does not distinguish by company size. It applies to every business that uses AI systems under its own authority in a professional context. The regulation does, however, explicitly task the Commission and the member states with supporting the efforts of providers and deployers, in particular SMEs.
Do we need a certificate?
No. The regulation prescribes no certificate and no minimum content. Documentation of who was trained on which tools and rules is sensible.
What happens if we do nothing?
The regulation itself sets no fine range for Article 4 (Art. 99(3) to (5)); member states lay down penalties nationally (Art. 99(1)). If damage occurs because someone used an AI tool incorrectly, missing training can matter under civil law. The RTR refers to § 1313a ABGB on this.
Does everyone need the same training?
No. The scope depends on prior knowledge, use and risk. Someone who only uses AI to draft text needs less than someone who processes customer data with it.
Did the obligation change in 2026?
Yes. Since 27 July 2026, Article 4 applies as amended by Regulation (EU) 2026/1744: providers and deployers take measures to support AI literacy, and a specific level per person does not have to be guaranteed. The obligation itself remains.
Which AI tools does your team use today? In the first call we clarify what should be regulated.
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