Did the Digital Omnibus change the Article 4 AI literacy rule?

What applies today

Article 4 has applied since 2 February 2025. As currently published, it requires providers and deployers of AI systems to ensure, to their best extent, a sufficient level of AI literacy among the people who use AI on their behalf. That is the live legal text right now.

What the Digital Omnibus proposes

On 7 May 2026 the Council and the European Parliament reached a provisional political agreement on the AI Omnibus, part of the wider Digital Omnibus simplification package first proposed in November 2025. One of its proposals rewrites Article 4. It would replace the duty to ensure a sufficient level of literacy with a softer duty to take appropriate measures to support the development of AI literacy among staff, without mandating a specific level of competence.

In plain terms, that would shift Article 4 from an obligation of result to an obligation of effort. The change reflects pressure from smaller organisations, which argued that a single enforceable standard was hard to apply across very different ways of using AI.

What is not settled

Two things are worth being precise about. First, the Omnibus is a provisional agreement, not law. It still needs formal adoption by the Parliament and Council and publication in the Official Journal before it takes effect, expected before 2 August 2026. Until then, the current Article 4 remains the applicable text. Second, commentary is mixed on how settled the Article 4 wording is in the agreed text, and supervisory bodies advised against weakening it. The safe reading today is that the softening is likely but not yet final.

The Omnibus also defers several high-risk obligations and adds simplifications for small and medium-sized enterprises, but it does not remove the AI literacy expectation. It reframes it.

What it means for your training

The practical answer does not change, and arguably gets clearer. Under the current standard you must ensure literacy. Under the proposed standard you must show you took measures to support it. Both are easiest to satisfy the same way: deliver training, test understanding, and keep a record that you did.

If anything, an effort-based standard raises the value of evidence. When the duty is to take measures, the question a reviewer or a customer's procurement team will ask is "show me the measures you took." A dated training record per person answers that directly, whichever version of Article 4 is in force when they ask.