In short
- The AI literacy obligation (Art. 4) has applied since February 2, 2025: since July 27, 2026 it requires taking measures to support staff skills, no longer ensuring a given level.
- No mandatory hours and no mandatory certification: what matters is proportionate measures and being able to show them.
- Obligations for high-risk systems used in education (admission, assessment, exam monitoring) move to December 2, 2027.
- Transparency (Art. 50) applies from August 2, 2026.
Obligations timeline
| Date | What applies |
|---|---|
| February 2, 2025 | Prohibited practices (Art. 5) and the AI literacy obligation (Art. 4). Applies to all deployers, schools and SMEs included. |
| July 27, 2026 | The Digital Omnibus enters into force: new Article 4 text ("take measures to support the development" of AI literacy) and new high-risk dates. |
| August 2, 2026 | Transparency obligations (Art. 50). |
| December 2, 2026 | New prohibited-practice provisions added to Art. 5; deadline for generative AI providers already on the market before August 2, 2026 to comply with content marking. |
| December 2, 2027 | High-risk systems in Annex III: including AI used in education for admission, assessment of learning and exam monitoring, and AI used for recruitment. |
| August 2, 2028 | High-risk systems in Annex I (safety components of products already covered by other EU legislation). |
What to do now
- Map who actually uses AI, with which tools and for what: it is the basis for proportionate measures.
- Scale training to risk: a baseline for people using generative tools to prepare materials, deeper training for anyone touching systems that affect assessments or decisions about people.
- Write clear usage rules: what can and cannot go into a chatbot, who checks the outputs, how students, families or customers are informed.
- Update your documents (AI plans, policies, training plans, circulars) that still quote "ensure a sufficient level".
- Keep a record of what you do: the Regulation does not require a register, but in an inspection the measures you can demonstrate are what counts.
In-depth articles
AI Act Article 4 rewritten by the Digital Omnibus: what changes for schools and SMEs
Since July 27, 2026 the Digital Omnibus has rewritten Article 4 of the AI Act: no longer ensuring a level of AI literacy, but taking measures.
Read →AI Act 2026: What Schools and SMEs Actually Need to Do
The AI Act promises protection, but feels like red tape. A practical checklist for schools and SMEs on what to do from August 2026.
Read →AI Act and PUIA: What Changes for Special Education from August 2, 2026
What Italy's institutional AI plan (PUIA) requires for special needs before using a chatbot with a student's data. Updated for the 2026 Digital Omnibus.
Read →AI training for school leaders and system administrators: my takeaways
An 8.5-hour AI course for school leaders and system staff: what it covers, what's missing, and how to count it in the staff training plan.
Read →Frequently asked questions
Does the AI Act apply to schools?
Yes. A school that uses AI systems in its activities is a deployer under the AI Act and must take the AI literacy measures required by Article 4. If it uses AI for admission, assessment of learning or exam monitoring, high-risk obligations also apply from December 2, 2027.
Did the Digital Omnibus abolish the AI training obligation?
No. Since July 27, 2026, Article 4 still requires providers and deployers to take measures to support the development of AI literacy among their staff. The wording changes: they no longer have to ensure a sufficient level, and the text states that no specific level has to be ensured for any person.
Is a certificate or a minimum number of training hours required?
The Regulation prescribes neither a number of hours nor a certification. What matters is taking proportionate measures and being able to demonstrate them: certificates and records are useful evidence, not a formal requirement.
Was August 2, 2026 the deadline for AI training?
No. The AI literacy obligation has applied since February 2, 2025. August 2, 2026 is when the Article 50 transparency obligations apply; Annex III high-risk obligations were postponed to December 2, 2027.