Where EU Member States Stand on Article 4 AI Literacy — and What It Means for Your Organisation
Most EU member states are facing the same problem: Article 4 of the EU AI Act has been in force since 2 February 2025, and almost none of them have published a formal AI literacy programme specifically designed for deployer organisations. The window to build a compliant programme before enforcement patterns form is shorter than it looks.
Key Takeaways
- Article 4 AI literacy obligations have applied across all 27 EU member states since 2 February 2025, to public sector institutions and private sector organisations equally
- As of mid-2026, no EU member state had published comprehensive formal guidance specifically addressing deployer AI literacy programmes
- Germany, France, Estonia, and Spain have relevant national AI initiatives but none specifically address deployer AI literacy requirements for organisations
- Article 4(3), added by the Digital Omnibus in July 2026, requires the EU AI Board to develop recommendations on AI literacy referencing European competence frameworks
- Organisations that build DigComp 3.0-based programmes now will be aligned with whatever standard the AI Board eventually sets
- The organisations moving first in each member state are establishing institutional track records before formal enforcement patterns form
Article 4 Applies Now, Across All 27 Member States
Article 4 of Regulation (EU) 2024/1689 requires that providers and deployers of AI systems "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." This obligation applies to all deployers: private companies, public institutions, NGOs, healthcare providers, financial institutions. There is no national exemption and no sector exemption.
Article 4 has applied since 2 February 2025, when Chapter I of the Regulation entered into force. The EU's national market surveillance authorities are responsible for implementation in each member state. What "sufficient" means, and how compliance is documented, remains an open question in every country.
Where Other Member States Stand
The honest answer, as of September 2026, is that most EU member states have not published formal guidance specifically addressed to Article 4 deployer compliance. Supervisory practice is still forming. The obligations are clear; the enforcement patterns are not yet.
Germany
Germany's federal AI governance is distributed across multiple bodies. The Bundesministerium für Arbeit und Soziales (BMAS) has been active on AI and work, including a national skills initiative that intersects with digital literacy. The Bundesministerium des Innern (BMI) oversees public sector digitalisation. Neither had published formal Article 4 deployer guidance as of mid-2026, though Germany's broader national AI strategy (Nationale KI-Strategie) includes upskilling commitments. Germany's scale means implementation will be slower to achieve uniformity than in smaller member states — which creates both a challenge and an opportunity for individual organisations willing to move before formal guidance arrives.
France
France has moved more visibly than most on AI governance. The Commission nationale de l'informatique et des libertés (CNIL) has been active on automated decision-making and GDPR-AI intersections. The French national AI strategy includes both public sector and private sector AI adoption, and France has been an active participant in EU AI Act working groups. However, as of the Article 4 enforcement date, no France-specific formal programme for deployer AI literacy — for public authorities or private companies — had been publicly documented.
Spain
Spain's AI governance runs through the Agencia Española de Supervisión de la Inteligencia Artificial (AESIA), established in 2023 and one of the first dedicated national AI supervisory bodies in Europe. AESIA has been publishing AI Act implementation guidance and is active on the AI literacy question across both public and private sector contexts. Spain's early investment in a dedicated AI authority puts it in a structurally stronger position than member states still deciding which ministry owns AI regulation.
Estonia
Estonia is a relevant comparator for Baltic and Northern European organisations specifically. Estonia's digital governance infrastructure is among the most mature in the EU: X-Road (the data exchange backbone), near-universal digital ID penetration, and a civil service that operates digitally as a default. Estonia's AI strategy includes public sector AI adoption, and the country has been piloting AI tools in public services for several years. That maturity means staff in both public institutions and private companies are using AI systems without necessarily having been trained to Article 4 standard. As of mid-2026, Estonia had not published a formal DigComp-mapped Article 4 programme, though its AI governance discussions are among the most sophisticated in the region.
The Broader Picture
The pattern across member states is consistent: strong national AI strategies, active regulatory bodies, but no published formal Article 4 compliance programmes specifically designed for deployer organisations. The reason is structural. Article 4 is requirements-based but output-vague: it says deployers must support AI literacy development, but does not specify what a sufficient programme looks like. That question is being answered by the AI Board under Article 4(3), and those recommendations are not yet published.
Article 4(3) and the Coming Standard
Article 4(3) was added by the Digital Omnibus Regulation in July 2026. It requires the EU AI Board to "adopt recommendations, taking into account European competence frameworks, to support the Commission and Member States in the promotion of AI literacy required under paragraph 1, including by setting out common objectives."
"European competence frameworks" in this context most clearly refers to DigComp, the European Digital Competence Framework published by the Joint Research Centre of the European Commission. DigComp 3.0, published in November 2025 (JRC 144121), is the current edition. It was published nine months before Article 4 enforcement started and includes significantly expanded AI-relevant competence statements across all five areas.
The AI Board has not yet published Article 4(3) recommendations. When it does, organisations across all 27 member states — public institutions and private companies — that are already working to DigComp 3.0 will find that their programme aligns with whatever standard the Board sets. Organisations that waited will be doing reactive retrofit.
What Any Organisation Can Do Now
The structural uncertainty across member states — no formal guidance, enforcement patterns still forming — is not a reason to wait. It is the window in which moving first has lasting value.
An organisation that builds a DigComp 3.0-based AI literacy programme now produces three things: documented competence records that satisfy Article 4 today, pre-alignment with the AI Board's likely competence standard, and an institutional track record that shows proactive compliance when formal enforcement patterns do arrive.
That applies equally to a Lithuanian public authority, a French private company, a German federal agency, a Spanish SME, or an Irish financial services firm. The obligation is the same across all 27 member states. The organisations that act before the standard is formally set are establishing their position rather than reacting to it.
The governance infrastructure in each country is there. The regulatory obligation has started. What is missing in most organisations is the programme.
Kelias offers a free 6-month AI literacy programme mapped to DigComp 3.0 and built for Article 4 compliance — open to public sector institutions and private sector organisations across the EU. Access at kelias.tech or contact joseph@kelias.tech.
Ikpong Joseph Alexander holds an MSc in Artificial Intelligence and is the founder of Kelias. Sources: Regulation (EU) 2024/1689, Article 4 (as amended by Digital Omnibus, Regulation (EU) 2026/1744, July 2026); JRC144121 DigComp 3.0, Joint Research Centre, November 2025. This post does not constitute legal advice.