Article 4 of Regulation (EU) 2024/1689 imposes a direct obligation — separate from the high-risk regime — on every provider and every deployer of an AI system: ensure, to their best extent, a sufficient level of AI literacy of staff and other persons dealing with the operation and use of AI systems on their behalf. The obligation is in Chapter I and has been in force since 2 February 2025 under Art. 113(a). It applies regardless of risk classification, regardless of company size, regardless of whether personal data is processed. The standard is contextual: it must take into account technical knowledge, experience, education, training, and the persons or groups of persons on whom the AI systems are to be used.
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Article 4 is short — a single paragraph — but its scope is broad. The Regulation defines AI literacy in Art. 3(56) and Article 4 operationalises it as an obligation on providers and deployers.
Art. 4 applies to staff and other persons dealing with the operation and use of AI systems on the provider's or deployer's behalf. That includes the marketing team using a generative tool, the HR team using a screening AI, the customer service team using a chatbot, the finance team using a forecasting model. Each role needs literacy proportionate to its use — but every role using AI is in scope.
Art. 3(56) defines AI literacy as skills, knowledge and understanding that allow informed deployment of AI systems and awareness of opportunities, risks and possible harm — taking into account rights and obligations under the Regulation. Generic IT or GDPR training does not cover the AI-specific elements: Art. 5 prohibitions, Annex III high-risk categories, Art. 50 transparency, deepfake risks, model limitations and bias, human-oversight expectations under Art. 14.
Art. 99(1) — Member States shall lay down rules on penalties applicable to infringements of the Regulation. While Art. 4 is not in the Art. 99(4) €15M / 3% tier, breaches are sanctionable under the national penalty regime each Member State sets. In addition, failure to train staff is a contributing factor that aggravates other breaches — for example, a serious incident under Art. 73 caused by an untrained operator, or a transparency breach under Art. 50 caused by staff who did not know the obligation existed.
Answer these four questions to determine your obligations.
12 PDF documents generated from your inputs. Each cites the article of Regulation (EU) 2024/1689 it fulfils.
Identifies whether your system is prohibited (Art. 5), high-risk (Art. 6 + Annex III) or subject to transparency obligations (Art. 50).
The 9 blocks of Annex IV in full: system description, training data, validation, performance metrics, risk management, human oversight. Art. 11 + Annex IV.
Signable document conforming to Art. 47 and Annex V.
Key application dates: 2 Feb 2025, 2 Aug 2025, 2 Aug 2026, 2 Aug 2027. Art. 113.
Executive summary of compliance status for authorities or commercial buyers. Art. 43 procedure.
QMS structure covering the 13 aspects required by Art. 17.
Document for the entity deploying your system, conforming to Art. 13.
Verifiable evidence list, cross-referenced to every Annex IV block.
Notification protocol conforming to Art. 73 (15 days general / 10 days death / 2 days widespread).
Training plan conforming to Art. 4, in force since 2 February 2025.
Plan structure required by Art. 72 and integrated into the technical documentation under Annex IV(9).
Template under Art. 27 for public bodies, private entities providing public services, and Annex III 5(b)(c) deployers.
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12 documents. 45 minutes. €249. The documentation your system needs before being placed on the market.
If your system falls under Art. 43(1) (Annex III point 1 biometrics with notified-body route, or Annex I products), you will need third-party conformity assessment. That is a separate process. AICheck does not replace it.
We do not sell audits. We do not sell consultancy. We sell the tool that structures your documentation under Annex IV.
Article 99 of Regulation (EU) 2024/1689. Chapter XII (Penalties) applies from 2 August 2025.
Art. 99(3). Up to €35 million or 7% of total worldwide annual turnover, whichever is higher. For SMEs and start-ups: whichever is lower (Art. 99(6)).
Art. 99(4). Includes failure to draw up technical documentation under Art. 11 + Annex IV. Covers obligations of providers (Art. 16), deployers (Art. 26), authorised representatives (Art. 22), importers (Art. 23), distributors (Art. 24), notified bodies (Art. 31, 33, 34) and transparency under Art. 50.
Art. 99(5). Applies when information provided to notified bodies or national competent authorities is wrong or misleading.
If you operate multiple AI systems and need to document them all under Annex IV, contact us for volume pricing at hello@solidwaretools.com.
Request volume pricingAICheck produces a document structured under Article 11 and Annex IV of Regulation (EU) 2024/1689 from the information you provide. The accuracy, truthfulness and completeness of that information is your responsibility as provider of the AI system.
We guarantee that the document structure follows Article 11 and Annex IV of Regulation (EU) 2024/1689 and that the legal references cited are correct as of the last verification date. We do not guarantee that a specific document will be accepted by a market surveillance authority in a given case, nor by a commercial buyer in a procurement process.
AICheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.
Twelve documents. Annex IV fully structured. Regulation (EU) 2024/1689. Your data does not leave your machine. The ZIP you download is yours to keep.