Aptenio
AI Act · Art. 4 · since 02/2025

The AI competence duty — explained for SMEs.

Since 2 February 2025, the EU AI Act requires a sufficient level of AI competence in your operations. What that means in practice, who it affects and how you put it into place — all on this page, without scaremongering about fines.

The duty in brief

What Article 4 lays down

The AI Act (Regulation (EU) 2024/1689) has been in force since August 2024. Article 4 on AI competence applies since 2 February 2025 — it affects SMEs that merely use AI, too.

Article
Art. 4

Providers and deployers must ensure a sufficient level of AI competence among their staff.

Applies since
02/2025

The competence duty has applied since 2 February 2025 — regardless of the risk class.

Affects
Deployers

Anyone using AI in their operations (e.g. ChatGPT, copilots) already counts as a deployer.

In plain terms

What “sufficient AI competence” means

Article 4 obliges providers and deployers to take measures, to their best extent, to ensure that their staff — and other persons dealing with AI on their behalf — have a sufficient level of AI competence.

“Sufficient” depends on the context: it takes account of the technical knowledge, experience and education of those involved, the specific area of use, and the groups of people the AI is applied to. So there is no fixed number of hours — but a traceable, appropriate build-up of knowledge.

Competence means: understanding what the tool can do and where its limits lie — assessing results, recognising risks, protecting data. Paraphrased from Art. 4 · Regulation (EU) 2024/1689
Who it affects

Provider or deployer?

The duty applies to both roles. For most technical SMEs the second one is decisive — merely using AI is already enough.

Role A

Provider

Develops an AI system (or has it developed) and places it on the market or puts it into service under its own name or brand.

Usually applies to software and product manufacturers.
Role B

Deployer

Uses an AI system under its own authority in its operations — for example ChatGPT, Microsoft Copilot or AI features in CAD/ERP software.

That is most SMEs. Even without developing anything themselves.
Timeline

Deadlines at a glance

The AI Act enters into application in stages. For AI competence, the deadline has already been reached.

08/2024

Regulation in force

Regulation (EU) 2024/1689 enters into force — the start of staggered application.

02/02/2025

AI competence (Art. 4) & prohibited practices

The competence duty applies — regardless of the risk class. Prohibited AI practices are banned.

08/2025

Obligations for general-purpose AI models

Transparency and governance obligations for GPAI models take effect.

08/2026

High-risk systems (Annex III)

The bulk of the obligations for high-risk applications become effective.

08/2027

High-risk in regulated products

Extended deadline for AI in products that are already subject to other EU product regulation.

Checklist

Five steps to AI competence

A pragmatic path — understandable, documentable, without a bureaucratic monster.

01

Take stock

Which AI tools are in use — officially and unofficially? Who uses what, and for what?

02

Clarify roles & risks

Provider or deployer? Which areas of use, which data, which risk class?

03

Train the team

In-house and on real tasks: possibilities, limits, prompting, source criticism, data protection.

04

Set up an AI policy

Clear rules: approved tools, how to handle company data, what may go to the cloud and what may not.

05

Document & refresh

Record trainings, rules and approved tools traceably — and update them regularly.

Frequently asked

Answered in brief

Does this also apply to small businesses?

Yes. Article 4 does not depend on company size. As soon as AI is used in your operations, the competence duty applies — including in small plant-construction or manufacturing businesses.

Is a one-off training enough?

A good start, but competence is ongoing: tools and use cases change. A recurring refresher plus a well-maintained AI policy makes sense.

What needs to be documented?

It should be traceable which trainings took place, which rules apply and which tools are approved. No bureaucratic monster — but reliable.

How does Aptenio help, concretely?

We train your team in-house on real tasks and accompany the implementation, including AI policy and documentation — ready for the AI-Act duty.

Note

This page provides a plain-language overview and is not legal advice. The wording of Regulation (EU) 2024/1689 prevails; consult qualified advice for your specific case.

Turn the duty into real competence.

We train your team in-house, hands-on and data-protection-compliant — and accompany a clean implementation. Request the course overview.