Ales Frelih

Every headline about the EU AI Act is about a deadline — usually 2 August 2026. But the obligation most likely to catch an ordinary small company has no deadline left to wait for. It has been law since 2 February 2025. And most businesses have done nothing about it, because it never came with a countdown.

It is Article 4: AI literacy.

What Article 4 actually says

Article 4 requires that providers and deployers of AI systems ensure their staff have “a sufficient level of AI literacy.” Crucially, it does not demand that everyone become a data scientist. The regulation says the measures should be proportionate — matched to your people’s technical knowledge, experience, education, and the context in which the AI systems are used.

Read that carefully. It is not asking for perfection or expertise. It is asking that you did something deliberate, and that you can show it.

The one question that decides everything

Strip Article 4 down and it comes to a single test:

If an authority — or an enterprise customer running due diligence on you — asked “show me your AI literacy measures,” could you?

For most small companies the honest answer today is no. Not because they are reckless, but because “we talked about it” and “everyone kind of knows how we use AI” leave nothing behind. Article 4 is not caught by good intentions. It is caught by a record.

The three documents that answer “show me”

The good news is that compliance here is not a project. It is a short stack of paperwork:

1. A written AI literacy policy. One page that states what your company does with AI, who is responsible for it, and how you keep it current.
2. A training record. A dated, signable list of who was trained, when, and on what. This is the single page that turns “we probably did something” into evidence.
3. The supporting templates. The documents that keep the first two alive instead of dying in an inbox — so the record is still true in six months.

That is the whole job for a typical 10–249 person company. An afternoon of work, not a compliance department.

The mistakes that actually get companies caught

• Assuming size exempts you. Article 4 applies to providers and deployers of AI systems. There is no headcount exemption. What scales with size is what is “reasonable” — not whether the rule applies.
• Confusing usage with literacy. Your team using ChatGPT every day is not evidence of literacy. A dated policy and training record is.
• Waiting for 2 August. Article 4 has been in force since February 2025. The August date belongs to Article 50 (transparency). Waiting for the wrong date is how the gap stays open.

What I would do this weekend

If you have nothing written down, do not overthink it. Write the one-page policy. Record who has been trained and on what. Save the templates that keep it current. Date everything. That single step moves you from “exposed and hoping” to “documented and calm.”

Not sure where you stand? Start with the free 2-minute self-check → it tells you exactly which obligations apply to you. If Article 4 is your gap, the AI Literacy Rapid Kit (€49) is those three documents, ready to fill in. Link: linktr.ee/frelih

---

This article was written by me and edited with AI — the kind of disclosure Article 50 is about. It is general information on the EU AI Act, not legal advice.