AI Act AI Literacy Rules for Irish Businesses (Updated July 2026)

Who the AI literacy duty applies to

Article 4 of the EU AI Act (Regulation (EU) 2024/1689) applies to "providers" and "deployers" of AI systems. A deployer is any person or organisation using an AI system under its authority, except where the AI system is used in the course of a personal, non-professional activity. In practice, a business whose staff use AI tools for their work is a deployer.

There is no minimum company size. The duty applies to sole traders and SMEs as well as large firms, although what counts as a reasonable measure depends on how you use AI.

What changed on 27 July 2026

From 2 February 2025, the original Article 4 required providers and deployers to take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff.

Regulation (EU) 2026/1744 (the "AI Omnibus"), published in the Official Journal on 24 July 2026 and in force from 27 July 2026, replaced Article 4. The duty is now to "take measures to support the development of AI literacy" of staff and other people operating or using AI systems on your behalf, taking into account their technical knowledge, experience, education and training, the context the AI is used in, and the people it is used on.

The new text adds: "This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual." The Commission and Member States must support businesses, in particular SMEs, and the Commission must publish practical examples of how to comply.

Practical steps for an Irish business

The Act does not prescribe a format for AI literacy measures. A proportionate approach for most small businesses looks like this:

• List the AI tools your staff actually use, and for what tasks
• Write a short AI use policy: which tools are approved, what information must never be entered into them (for example customer personal data or confidential material), and when a person must check the output
• Give staff a short briefing matched to their role and the tools they use, covering what the tools are good and bad at
• Keep a simple record of what you did and when, so you can show the measures you took
• Review the policy when you adopt a new AI tool or start using AI for a new purpose

Fines and enforcement

The AI Act's own fine tiers in Article 99 cover other provisions, such as prohibited AI practices and specific obligations of operators; Article 4 is not among the provisions listed there. Member States lay down the rules on penalties for infringements of the Act more generally, so keeping a record of your measures remains sensible.

Using AI for personal data also brings GDPR into play. Putting customer or employee personal data into an AI tool is a data processing decision in its own right, separate from the AI Act.

If you use AI for higher-risk purposes

Some uses are classified as high-risk under the AI Act, for example AI used to screen or rank job applicants. These carry much heavier obligations than AI literacy. Regulation (EU) 2026/1744 moved the date these high-risk rules apply to 2 December 2027 for systems listed in Annex III (which includes employment uses) and 2 August 2028 for systems covered by Annex I. If you use AI in recruitment or similar decisions about people, get specific advice before those dates.