EU AI Act · Article 4

If anyone on your team uses ChatGPT,
you're legally required to document their training.

Since February 2025, Article 4 requires a documented AI-literacy programme — for any EU business whose staff use ChatGPT, Copilot, AI screeners, or any generative tool. National enforcement begins August 2026. Stone & Carter writes, delivers, and documents yours. Audit-ready folder in 7 days.

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Article 4 compliantImplementation free until May 31Cancel anytime

Three questions. One answer.

AI in use?

One employee using ChatGPT
once is enough to trigger it

EU operations?

Established in the EU
or employing EU staff

Any staff?

No size threshold.
Sole traders are exempt.

If all three: Article 4 applies to you now.

Regulation (EU) 2024/1689 · Article 4

What the law says. No interpretation.

"Providers and deployers of AI systems shall 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..."

— Article 4 · Regulation (EU) 2024/1689

Who it applies to

Every EU employer whose staff uses AI at work. ChatGPT, Copilot, Gemini, or any embedded AI feature. Sector doesn't matter. Headcount doesn't matter. One user is enough.

What 'sufficient' means

The Commission's published guidance is clear: role-appropriate, ongoing, documented training — not a one-off session. An annual PDF in a drive explicitly does not satisfy the obligation.

What happens in August 2026

National enforcement begins. Member-state authorities begin inspections. Missing literacy programmes will be an aggravating factor in any AI Act review — not a standalone fine, but compounding evidence.

Maximum fine

€15M

or 3% of global annual turnover — whichever is lower for SMEs

A €2M company faces up to €60,000 in exposure. A €10M company: €300,000. The fine is proportional to your revenue.

Stone & Carter Starter costs €150/month. That's €1,800/year — against €60,000–300,000 in exposure for a typical SME. The maths aren't close.

Your exposure

You're already liable.
You just haven't been asked yet.

Article 4 doesn't wait for enforcement to begin. The obligation started February 2, 2025. Every day without a documented programme is a day with exposure and no defence.

The obligation

Feb 2025

Article 4 became applicable

Not August 2026. Not when enforcement begins. February 2, 2025. You've had an obligation for over a year. Most companies have done nothing.

The gap

< 1%

of your staff have documented AI literacy training

A PDF in a shared drive doesn't satisfy Article 4. An LMS course doesn't either, unless it's role-tailored, ongoing, and produces an audit trail. Almost no company has this.

The fine

3%

of global annual turnover — not just €15M

For a €2M company: €60,000 at risk. For a €10M company: €300,000. The fine scales with your revenue. So does the cost of building nothing.

How it works

10 minutes from you. 7 days to compliance.

You spend half an hour with us on day one. We do everything else. The Compliance Folder is populated on day 7. Training runs automatically every week after that.

01

10-minute audit call

We map your AI tools, team structure, and risk surface against Article 4. You leave with a gap analysis and a programme design — not a proposal for more consultancy.

02

We write your role-tailored curriculum

Five tracks — Finance, HR, Sales, Ops, Leadership — each built from real incidents in your sector. Not generic AI principles. Actual scenarios your team will recognise.

03

Programme activates on day 7

Lessons land in inboxes. Two minutes a week. No LMS to install. No new login for staff. Completions and scores logged automatically from day one.

04

Compliance Folder delivered at activation

The full evidence file is ready before a single lesson is completed. You have documentation on file from the moment your programme starts — not 12 weeks later when staff finish.

05

We maintain it as the law evolves

Quarterly curriculum reviews, automatic Folder updates, no legal retainer required. As the Commission issues new guidance and national authorities clarify enforcement, your programme stays current.

Pricing

Less than a compliance lawyer's afternoon.

Every plan includes a fully populated Compliance Folder, five role tracks, and quarterly curriculum reviews. The deliverable your regulator would accept — maintained for as long as your obligation runs.

Starter

Up to 30 staff

€3/person/mo
  • Article 4 Compliance Folder — populated on day 7
  • All 5 role tracks included
  • Email delivery, no LMS install
  • Quarterly curriculum reviews
  • Admin dashboard
Get in touch →
Most chosen

Growth

31–100 staff

€5/person/mo
  • Everything in Starter, plus:
  • Completion analytics dashboard
  • Priority support — next business day
  • Custom role configuration
  • Expanded scenario library
  • Onboarding call with compliance advisor
Get in touch →

All prices in EUR. VAT may apply. Implementation waived for contracts signed before May 31, 2026.

Hard questions

The objections worth taking seriously.

"Can't we just handle this internally?"+
You could — if your compliance team has Article 4 expertise, can write role-tailored scenarios across five functions, and can produce the specific evidence format regulators expect. Most can't. We've built this infrastructure once, across dozens of clients. You're buying the output: a populated Compliance Folder on day 7, not six months of internal project management.
"We barely use AI."+
One employee opening ChatGPT once is enough to trigger Article 4. The obligation tracks employee behaviour, not your company's official AI strategy. If IT doesn't know about it, that doesn't change your exposure — it makes it worse, because it means there's no governance at all.
"What if the regulation changes?"+
We review every curriculum quarterly as the Commission issues new guidance and national authorities clarify their enforcement approach. Your programme updates automatically. You don't need a legal retainer to stay current — that's part of what the monthly fee covers.
Start here

Every day without a programme
is a day with exposure and no defence.

The gap analysis call is 10 minutes. We map your obligation, identify what you're missing, and tell you exactly what a programme for your company would cost. No slide deck. No obligation.

10 minutes · No commitment · Audit-ready programme within 7 days of signing