AI literacy under Art. 4 AI Act: what SMEs must do after the omnibus

The Bundesnetzagentur says the literacy obligation has applied since 2 February 2025. It identifies the amendment as Regulation (EU) 2026/1744, entering into force on 27 July 2026.

The Commission's amended guidance describes an obligation to support the development of literacy without mandating a specific or sufficient level for an individual. That supports a practical distinction: organise relevant measures and follow-up, rather than promising that attendance guarantees a person's competence.

The source versions are not fully aligned. The RTR operator guidance still uses the earlier sufficient-level formulation. Treat this as a source-version conflict. Do not combine the older formulation with newer dates and present the mixture as settled statutory wording.

Before quoting the provision in a policy or contract, obtain the readable promulgated amendment and consolidated text. Check the wording in the original regulation and amendment. A regulator's FAQ is guidance, not the legislation itself.

The Bundesnetzagentur's literacy guidance covers providers and deployers irrespective of sector or organisation size, and includes general-purpose chatbots. However, its scope guidance also distinguishes private use and the territorial reach of the rules. A worldwide claim that every business using any chatbot has the same obligation would go too far.

For your internal review, describe the organisation's role and the actual use. Ask who selects the system, who supplies information, who checks the answer and who authorises an action. Include people working on your behalf when assessing the relevant audience. Refer uncertain scope questions to the person responsible for legal review.

We recommend keeping the inventory concrete. Instead of recording only “office AI”, write “prepares replies from approved service instructions” or “extracts fields from supplied documents”. Add the system owner and users.

Include informal uses in that discussion. Ask staff which tasks they already attempt and where they feel uncertain. Use the answers to decide what needs instruction, what needs a clearer rule and what should remain outside the approved process. Avoid treating an empty inventory as proof that no support is needed.

Start with the decisions people face. A person preparing a draft needs to identify the source and missing information. Someone approving the draft needs to check what the organisation would commit to. IT needs a clear route for configuration questions and reported failures. Management needs to decide where use is acceptable and who owns the remaining problems.

Use the following table to plan learning. Adapt the exercises to your approved tasks and existing knowledge.

Provide a shared introduction to approved tools, permitted inputs, sources and escalation. Then vary the depth by role. Do not require office staff to memorise technical architecture when the immediate learning need is recognising a missing approval. Conversely, do not assume technical experience establishes familiarity with your business rules.

Use a synthetic service enquiry. The supplied case says the customer requested an appointment, the booking has not been approved, and the contact record must be checked before any reply. The deliberately incorrect draft says that the appointment is confirmed and uses an unverified recipient.

Ask the participant to mark the unsupported claim, identify the authoritative information and decide what happens next. The expected response is to stop the proposed confirmation, check the recipient and request a booking decision. A stylistic rewrite alone does not meet this exercise's objective.

Discuss the decision in ordinary language. Which sentence made a commitment? Which source would justify it? Who can resolve the gap? Keep the discussion tied to the supplied case rather than turning it into a general quiz about AI terminology.

Repeat the exercise with a changed detail when useful. The appointment might be approved while the recipient remains uncertain. The participant should inspect the new evidence rather than repeat a memorised rejection. Record whether the instructions helped and what explanation was missing.

Treat this as a way to identify support needs. Set review criteria and training duration for the task, and check any applicable legal requirements before describing the exercise as mandatory. The operational review process is developed further in draft and sign-off.

The Commission says a certificate is not needed and allows internal records of training or guidance. The Bundesnetzagentur recommends documenting measures, content, time and participants, alongside evaluation and refreshers. The fields below translate that guidance into an optional working record.

Use references to controlled examples where possible. A record does not need to reproduce every business document used during instruction. Decide who may see the record and where it belongs in your existing document management process.

Write down incomplete activities honestly. If staff could not finish because a source was missing, record that result and assign the source problem. Do not convert planned content into a claim that it was delivered. Determine the appropriate retention period and handling for your organisation separately.

The Commission's answer on certificates is clear: none is required. That does not make every course unsuitable. It means the purchasing decision should focus on relevance to the work rather than treating a certificate as the obligation itself.

Ask whether the material uses your approved tasks, distinguishes legal guidance from recommendations, and provides a way to handle unresolved questions. Request an explanation of how changed systems or instructions will be addressed. A generic presentation may contribute to an introduction, but decide what workplace guidance still needs to accompany it.

At modernagents, team training is part of implementation, as described in the company facts. Plan instruction alongside the workflow, source rules and approval process.

The Commission's Q&A gives 3 August 2026 in one enforcement answer and 2 August 2026 in the next. Verify the applicable date against the legal text and national implementation before relying on either answer as a deadline.

The same Commission guidance describes possible national penalties and enforcement measures, with national law and proportionality relevant. Check the applicable national fine provisions. General maximum AI Act fines should not be presented as the automatic sanction for a missing literacy measure.

For an Austrian or German deployment, check the current implementing provisions, responsible enforcement authority and applicable sanction route. An organisation publishing guidance is not, for that reason alone, established as the enforcement authority for your case. Keep these questions in the legal review rather than filling the gaps with a course provider's claim.

Assign an owner for the working instructions and unresolved questions. Review the material when the task, approved data, system or approval process changes. Include new colleagues and deputies in the planning. Check whether specific refresher requirements apply to your organisation.

Bring recurring uncertainty back into the project. If people cannot identify the current source, improve its labelling and ownership. If the approval rule is ambiguous, have the business owner clarify it. More instruction should not become the permanent answer to an undefined process.

Use the AI usage policy guide to turn decisions into instructions. The wider AI Act guide provides context. Begin introducing AI with a documented task, a responsible owner and a case that shows where staff need help.