AI literacy: the Article 4 training obligation is already in force

What Article 4 says

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 systems are to be used in.

Note the subject: not only those who build AI, but also those who use it. A company whose customer-service staff work alongside an AI assistant is squarely in scope. So is a company whose marketing team drafts copy with a language model.

Why it is the most neglected obligation

Because it has no headline deadline: it came into force quietly, alongside the ban on prohibited practices, and made no news. And because it is worded elastically — "to their best extent", "sufficient level" — which convinced many that it was a recommendation.

It is not. It is an obligation, and one whose result must be demonstrable: the question you will be asked is not "did you do training?" but "show me what you did".

An elastic obligation is not a weak one: it is an obligation you have to fill with content yourself, and document.

What "sufficient level" means

The provision sets no hour count and no syllabus. It sets a criterion: the level must be proportionate to the person's role, to the system's risk and to the context of use. Whoever configures a chatbot's instructions needs to know things that whoever uses it to answer customers does not, and vice versa.

• People who use AI daily must know what the system can and cannot do, where it typically fails, and when not to trust the output.
• People who configure it must know which obligations bind the company, and how their choices satisfy or breach them.
• People who decide must be able to classify risk and know which uses Article 5 prohibits outright.
• Everyone must know what never goes into an AI system: third-party personal data, trade secrets, confidential customer information.

How you prove it

With three things, none of which is the training itself: a written programme (who trains whom, on what, how often), a register of the sessions delivered (date, attendees, contents, duration), and individual certificates.

That is the only part visible from the outside. Training done well but never recorded is worth, in front of an authority, exactly as much as training never done.

Training is eligible for the Chamber of Commerce voucher

Staff training costs are an eligible line in the Italian Chambers of Commerce "Voucher Doppia Transizione" schemes, where the local Chamber has joined. It is one of the rare occasions when a legal obligation coincides with a cost somebody else co-finances. Contribution rates and ceilings vary from Chamber to Chamber: the local call is the only authoritative source.

One point makes all the difference: for consultancy and training, nearly every call admits only a closed list of qualified supplier categories — explicitly including innovative start-ups. That is not a box a generic software vendor ticks.