The AI requirement left standing when the rest was postponed
Written by AI · Translated by AI · Read the Swedish original
Most of the AI Act was postponed to 2027. The AI literacy requirement stayed, but was rewritten from ensuring a level to supporting the development of one.
Most of the EU AI Act that was due to apply on 2 August was postponed. The requirements on standalone high risk systems moved to 2 December 2027, the requirements on AI built into regulated products to August 2028. One obligation stayed on the original date: Article 4, the requirement that staff be AI literate. Since 2 August, national market surveillance authorities can examine how providers and deployers live up to it.
Six days earlier the obligation had been rewritten. The digital omnibus on AI entered into force on 27 July. Article 4 previously required measures to ensure a sufficient level of AI literacy among staff. It now requires measures that support the development of it, and no set level is to be guaranteed for any individual. The requirement went from outcome to effort in the same week that the outcome could be examined for the first time.
The difference is not legal fine print. A training course completed can be documented. A training course understood cannot, and only the second one matters on the day an AI system answers wrongly and nobody in the room reacts. Article 4 has applied since February 2025, so what employers can now be examined against is eighteen months that should already have been used.
In Sweden the government appointed PTS, IMY, Finansinspektionen, Läkemedelsverket and Swedac as competent authorities under the regulation on 25 June. The mandate runs until 31 December 2026. The obligation that reaches widest, every organisation that lets anyone use an AI system at work, is the one about what staff understand. Supervision of it rests on a mandate that expires in four months.
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Why does it matter?
The postponement reads easily as the AI Act not applying yet. For most employers the opposite is true: the part that reaches widest, the requirement about what staff understand of the systems they use, is the one that did not move and that can now be examined.
What is the background?
The AI Act has been phased in since 2024. Article 4 on AI literacy began to apply on 2 February 2025, but without any authority having the power to examine it. The digital omnibus on AI, which entered into force on 27 July 2026, moved the heavy high risk requirements forward and left Article 4 in place.
What is uncertain?
The requirement is an obligation to make an effort, not to succeed. No set level of knowledge is to be guaranteed for any individual employee, and there is no established standard for what counts as sufficient measures. How hard it is actually examined is still unknown.
What does it mean in Sweden?
On 25 June the government appointed PTS, IMY, Finansinspektionen, Läkemedelsverket and Swedac as competent authorities under the regulation, with a mandate that runs until 31 December 2026. IMY is the market surveillance authority for AI systems in areas including law enforcement and credit scoring.