Control over AI
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Compliance and AI 5 min read

Does every employee need AI training?

Article 4 asks for measures suited to each role and context, not one course for everyone. What applies to every employee, what differs by role and what else it takes.

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Quick answer

Not the same training, at any rate. Article 4 of the AI Act asks for measures aimed at a sufficient level of AI literacy, matched to the knowledge, experience and context of whoever uses AI on the organisation's behalf. For most employees a short briefing on the basics is enough: which tools are allowed, which data stays out of a prompt and that answers need checking. Anyone using AI in decisions about people, or assessing AI tools, needs more.

01

Map which groups in your organisation use AI, and for what

02

Give everyone who uses AI the same short grounding, for example fifteen minutes in a team meeting

03

Have someone who knows each system train the people who use it in decisions about people

04

Make the decision on each tool easy to find when someone opens it

05

Record for each role what people received and when; no certificate needed

A team lead at an engineering firm finds an invitation in his calendar: AI Act training, two hours, mandatory for all staff. In his team of forty, thirty people use Copilot for emails and reports, four colleagues in procurement assess suppliers and two people in recruitment have just started using a tool that pre-sorts applications. He wonders whether those three groups really belong in the same two hours.

They do not, and the law does not require it. Article 4 of the AI Act asks for measures aimed at a sufficient level of AI literacy, matched to knowledge, experience and the context in which someone uses AI. One course for everyone is one way to meet that, but it is not the benchmark. What Article 4 says exactly, and who supervises it, is covered in AI literacy in 2026. This piece deals with the next question: who needs what?

What does Article 4 ask of a team?

The provision is addressed to the organisation, not to the individual employee. It is the employer who takes measures, bearing in mind what people already know, what they do and who the system is used on. The Digital Omnibus of July 2026 turned it into a best-efforts obligation: take measures that support the development of AI literacy.

The key word is "matched". An employee who uses a chatbot to make a report more readable does not need to understand how a language model is trained. Someone who pre-sorts applicants with a system does need to understand what that system weighs up and when to override it. The same training for both is too much for the first and too little for the second.

What does apply to everyone who uses AI?

Three things, and they fit on one page.

Which tools the organisation has allowed, which it has not and where to look that up. Which data does not belong in a prompt: customers' and colleagues' personal data, confidential documents, anything covered by a duty of confidentiality. And that an AI answer is a draft that someone checks before it leaves the building. What can and cannot go into a prompt is set out in more detail in what not to share with AI.

Everyone who works with AI needs these basics, including contractors who use the organisation's systems. Article 4 refers to staff and other persons who use AI systems on the organisation's behalf. Strictly speaking, someone who only uses a calculator and the phone falls outside it. In practice more and more ordinary software has AI built in, so a short briefing for the whole organisation is the simplest approach.

Who needs more than the basics?

Three groups turn up in almost every organisation.

GroupWhat they need on topWhat form works
Uses a chatbot for writing (most people)Nothing beyond the basicsA short briefing, with the decision on each tool visible while they work
Uses AI in decisions about people (recruitment, appraisal, customer onboarding, care)How the system reaches an outcome, what it misses, when to override it, who oversees itInstruction on each system, given by someone who knows it
Assesses or buys AI tools (IT, procurement, privacy)Vendor, home country, training policy, data processing agreement, riskA questionnaire and the register of assessed tools
Sets the policy (management, team leads)The status of each tool, where the line between allowed and not allowed lies, their own responsibilityThe policy itself and the decisions in it

The second row is the most demanding, and also the one the AI Act says most about. AI used for recruitment, appraisal, promotion or dismissal is listed as high-risk in Annex III, and from 2 December 2027 the obligations in Article 26 apply to it, including human oversight by people with the competence and authority to intervene. Whoever provides that oversight has to know the system. A general course will not achieve that; it has to be done system by system. What else applies to this group is covered in the EU AI Act for employers.

What does that mean for the team of forty?

Back to the engineering firm. The team lead compares the invitation with his own list. The thirty Copilot users get the basics: fifteen minutes in the team meeting, the list of allowed tools and the rule on client data. The four buyers get the questionnaire the firm uses to assess tools and go through it once with the privacy officer. The two colleagues in recruitment get something else: a briefing from the vendor on what the pre-sorting tool weighs up, and the rule that a person reviews every rejection.

Two months later an inventory shows that ChatGPT and a meeting transcription tool are in use alongside Copilot. Nobody ever made a decision on the transcription tool. That is not proof that the briefing failed. It shows that the list of allowed tools from the team meeting is already out of date, and that the basics need a place where people can look up the decision when they are unsure.

How do people take the basics into their work?

The briefing lays the foundation. Then the work starts, with a deadline, a new tool or a text in which one sensitive detail is easy to miss. How training and support complement each other at that point is covered in our article on turning AI training into careful everyday work.

For Article 4, that means the basic briefing works well alongside a decision that reappears when someone opens an AI tool: this is what was decided about this tool and this is the approved alternative, and sensitive data in your text is highlighted before you send. People can then check the decision when they are unsure, and the team lead does not have to send the list round every month.

AI register
AllowedUnder reviewNot allowedAll tools
Search by tool, vendor, domain or former name…
1,012 tools
DeepSeek
Critical · 90/100
Not allowed
Otter.aiNew
High · 68/100
No decision yet
Grok
High · 67/100
Not allowed
ChatGPT
High · 62/100
Allowed
Perplexity
Medium · 55/100
No decision yet
HeyGen
Medium · 53/100
No decision yet

Every tool, scored for risk

Over 1,000 AI tools, each scored from Low to Critical. Nothing is approved or blocked until someone decides.

More about AI Governance

BeeSensible links a catalogue of AI tools to the use it sees in the organisation. The organisation sets the status of each tool, and every tool starts with the status "No decision yet". Anyone who opens a tool the organisation has decided on sees that decision in the browser. The figures on what happens next carry no user ID. The AI tools page explains how this works.

What should you record?

Not a certificate. For each role: what the group needed to know; which briefing they received, and when; which tool decisions went with it. The European Commission confirms in its questions and answers on Article 4 that your own records are enough; the main article linked above points to it. Add the aggregated figures on notices and highlights, and you also have something to say about the weeks after the briefing. The three kinds of evidence an auditor wants to see side by side are described in our article on demonstrating AI literacy, and more on the subject is under AI governance.

The two-hour invitation can stay. But the team lead sends it back with a question: which three groups do we have in this organisation, and what will each of them take away that they can still find next week?

FAQ

Common questions

Is AI training mandatory under the AI Act?

Not in that form. Article 4 asks for measures aimed at a sufficient level of AI literacy, matched to the role and the context. A course can be one such measure, but so can a short briefing, instruction on a specific system or a team discussion about what does and does not belong in a prompt. The law does not mention a course, certificate or number of hours.

Does AI literacy also apply to employees who do not use AI?

Article 4 covers the people who operate and use AI systems on the organisation's behalf. Strictly speaking, anyone who does not falls outside it. In practice much of the organisation uses something with AI built in, often without calling it that, and a short briefing on the basics for everyone is the simplest way to cover it.

Do contractors need the briefing as well?

Yes, if they work with the organisation's AI systems. Article 4 refers to staff and other persons who use AI systems on the organisation's behalf. An agency worker or a supplier using your tools is covered. The same short briefing on allowed tools and data is usually enough.

How often should the briefing be repeated?

Article 4 says nothing about that. A good trigger is a change: a new tool being allowed, a new decision about an existing tool or a new role. A short refresher in the team meeting at that point often works better than a fixed annual course.

How do you record what employees received without a certificate?

Role by role: what the group needed to know; which briefing they received, and when; which tool decisions went with it. The European Commission confirms in its questions and answers on Article 4 that your own records are enough. Add the figures on what happens during day-to-day work and you also have something to show for the weeks after the briefing.

Portrait of Rens Timmermans from BeeSensible

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