Civil servants, contractors and consultants who use AI agents for a public body all need sufficient AI literacy, and Article 4 of the EU AI Act makes the body take measures to ensure it. That literacy carries extra weight here: residents cannot choose another provider, decisions must be explained, and those who buy agents must understand them too.
What does Article 4 ask of a public body?
Article 4 applies to every provider and deployer of AI systems, including public authorities. In substance, they must take measures to ensure, to their best extent, a sufficient level of AI literacy among staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their knowledge, experience, education and training, the context of use, and the people the systems are used on.
AI literacy means the skills, knowledge and understanding to use AI systems in an informed way and to understand their opportunities, risks and possible harms. In public services, "the people the systems are used on" are residents, often including people in difficult circumstances. Whether formal training is required is covered in does the EU AI Act require AI literacy training.
Public bodies also face heavier duties for some uses. The Act treats certain public uses as high-risk, such as evaluating eligibility for public benefits and services, and public bodies using high-risk systems must carry out a fundamental rights impact assessment under Article 27. Public law adds its own duties of transparency and fairness.
Who does it cover?
- Caseworkers and front-line staff using agents on applications, enquiries and casework.
- Contact-centre staff answering residents with agent help.
- Policy officers using agents to summarise consultations and draft briefings.
- Procurement and commercial teams buying agents and writing contracts for them.
- Digital, data and IT teams configuring agents and their bounds.
- Contractors and consultants delivering services on the body's behalf with its agents.
- Senior officials and elected members accountable for services.
Procurement teams are a distinctive group. A public body that buys an agent without understanding depth, bounds, certification and the record cannot write a contract that protects residents. Literacy for buyers is as important as literacy for users. Who needs literacy in general is covered in who needs AI literacy under the EU AI Act.
What does literacy mean when public sector agents act?
A governed casework agent might read an application and records at depth 1, draft an assessment and letter at depth 2, process routine changes that cannot reduce entitlement at depth 3, and have awards, refusals, reductions and recovery held for a named caseworker.
Caseworkers need to read the facts behind a recommendation and their provenance. The body's own records are sealed, confirmation from another public body is signed, the resident's account is declared, and an anonymous allegation is external. A recommendation to reduce or recover money resting on external material must be challenged.
Contact-centre staff need to know what the agent may tell a resident about their case, recognise distress or vulnerability, and hand over to a person.
Policy officers need to know that an agent's summary of a consultation can flatten minority views, and to check it against the responses.
Procurement teams need to ask the right questions: how is depth earned, how often does certification lapse, what is withheld at the platform floor, and can the body reconstruct any decision from the record?
Everyone needs to know that an agent's certificate lapses after 90 days, and that a run that clears no depth drops it to depth 1 the same day. Services must keep running when that happens.
How does a public body meet Article 4?
| Requirement | Control | Evidence it leaves |
|---|---|---|
| Sufficient literacy for staff | Core module plus role modules for casework, contact centre, policy, procurement and digital | Records by role and directorate |
| Contractors and consultants | Contracts require training before agent access | Contract clauses; supplier evidence |
| Fitted to residents affected | Modules on vulnerability, explaining decisions and external allegations | Assessment results |
| Buyers understand what they buy | Procurement module on depth, certification, lapse and the record | Training records for commercial staff |
| Kept current | Briefings at agent recertification or rule changes | Briefing records |
| Leadership literacy | Sessions for senior officials and members | Minutes and attendance |
A step-by-step approach is set out in how to set up an AI literacy programme under the EU AI Act.
What will auditors and regulators ask?
Auditors, ombudsmen, data protection authorities and market surveillance authorities may ask: how do you decide what literacy each role needs? How are contractors trained? Did procurement understand what it bought? How do caseworkers check agent recommendations? How are residents told an AI system was involved, and how do they reach a person?
What does Article 4 not cover?
It does not set the rules of public services or administrative law. It does not replace Articles 14, 26 and 27 for high-risk uses. It does not prescribe course content or credentials. It does not cover residents' own literacy. Comparisons are in Article 4 in healthcare and in e-commerce.
This is an explanation of the rules, not legal advice; confirm how they apply to you with counsel.
Where the Academy fits
Pryme Intelligence Academy's Foundations track covers why agents must be governed, the decision chain, depth and certification, the workspace, what you pay for, and ownership, data and trust. That makes it a fit for procurement teams and senior officials as well as front-line staff, with a free badge that never expires. The levels are explained in AI literacy and certification for people who work with agents.
Questions people ask
Does Article 4 apply to a council chatbot answering bin collection questions?
Yes, if the council deploys it. The literacy needed for staff overseeing it is modest, and residents must be told they are talking to an AI system.
Are consultants covered by the public body's duty?
If they use the body's AI systems on its behalf, the body must take measures for their literacy. Contracts should set the expectation and require evidence.
Why should procurement staff be trained?
Because contracts decide what an agent may do, how it is certified and what the body can see. Buyers who do not understand those things cannot protect residents or the public purse.