What UK businesses need to know about the EU AI Act Article 4

February 2, 2025. That is when Article 4 of the EU AI Act—focusing on AI literacy—officially comes into force.

This will be relevant to you if your business:

–            operates in or trades with the EU;

–            develops, markets or uses AI systems.

So, what is Article 4 and what is AI literacy?

Article 4 is all about training and by that, we do not mean training the AI, we mean good old fashioned human training.  Businesses have a responsibility under Article 4 to ensure a sufficient level of AI literacy for anyone dealing with or using AI systems on the business’s behalf.

AI literacy is defined in the EU AI Act as having the “skills, knowledge and understanding” to make “informed deployment of AI systems, as well as to gain awareness about the opportunities and risks of AI and possible harm it can cause”.[1]

In summary, affected businesses must make sure that anyone involved in developing, managing, or using AI systems within the business understands how they work—and how to use them responsibly. Article 4 is about making sure people aren’t just blindly using AI tools—but instead understanding the specific AI system’s benefits, risks, and limits.

The training should match the individual’s role and responsibilities. For example, a software engineer might need technical training, while a customer support team might need to know how to handle AI-related queries ethically.

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Why should UK businesses care?

Even though the UK has left the EU, the EU AI Act can still apply to you if you do business in the EU.

Let’s say you’re a UK-based software company offering AI tools to clients in Germany—this law matters to you.

So, while it’s technically an EU law, its extraterritorial scope means UK companies dealing with the EU market should pay attention.

If you are adamant that your business has no dealings with the EU market you should still pay attention because until the UK government rolls out its own AI legislation no one can say for sure that the UK will not implement a similar rule to Article 4.

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What are the penalties for not complying with Article 4?

At the time of writing this the EU AI Act has not specified penalties for Article 4 non-compliance, however, there are suggestions from commentary of Article 99 (Penalties) that administrative fines for non-compliance of up to €15,000,000 or 3% total worldwide annual turnover, if greater, could apply.  Whilst this remains to be tested over time, no-one wants to be the test case so it is better to err on the side of caution.

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Practical tips for UK businesses

Now that you know what Article 4 is about, here’s how to prepare:

1. Audit your AI systems Take a closer look at the AI tools you’re using or developing or selling. Do you fully understand how they work? More importantly, does your team?
2. Train your team Start thinking about role-specific training. Managers, customer-facing teams and engineers will need tailored education on using or deploying AI responsibly.
3. Document everything Keep clear records of who’s been trained, what systems are in use, and how risks are being managed. The EU AI Act puts a strong emphasis on accountability.
4. Work with legal and tech experts If you’re unsure about compliance, consider speaking to legal or technical professionals. They can guide you on aligning with the law without overwhelming your operations.
5. Stay informed The Act’s provisions are rolling out in phases, so keep an eye on updates. Article 4, for instance, officially applies from February 2, 2025.

A final word

The EU AI Act isn’t just about compliance—it’s about fostering trust in AI systems. If your business is proactive in understanding and applying these regulations, it’ll show your customers (and partners) that you take AI ethics and safety seriously.

And if you’re feeling unsure or overwhelmed, don’t hesitate to seek help. Staying ahead of these changes will only strengthen your position in the market—EU or otherwise.

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[1] EU AI Act Article (3) Definitions no.56.