Do freelancers count as staff for training?
Often yes. Article 4 is not limited to employees on payroll.
Drafted with AI help and checked against the official EU text before publishing.
Often yes. Article 4 is not limited to employees on payroll. It covers staff and other persons dealing with the operation and use of AI systems on your behalf. A freelancer who uses your tools to serve your clients sits in that second group.
A freelancer who uses your tools to serve your clients sits in that group. A freelancer using AI only on their own unrelated clients, not on your behalf, is not your Article 4 person for that work. There is no official training certificate.
This is general information, not legal advice.
What the law actually says
Original text (2024), replaced 27 July 2026
"Providers and deployers of AI systems shall take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training and the context the AI systems are to be used in."
Amended. The Digital Omnibus on AI (Regulation (EU) 2026/1744, in force 27 July 2026) replaced Article 4. The duty is now to take measures to support the development of AI literacy, and it does not require you to guarantee any particular level. The quote above is the original wording — the European Commission has not yet published the consolidated text. We will quote it here the day they do.
— EU AI Act, Article 4 (original wording, amended 2026) (Regulation (EU) 2024/1689); in force from 2 February 2025 · eur-lex.europa.eu"Providers and deployers of AI systems shall take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf […]. This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual."— Article 4(1) as replaced by Regulation (EU) 2026/1744, Article 1(5)
In plain words
- The phrase is “staff and other persons … on their behalf”. That is wider than a contract of employment.
- “Sufficient” still depends on the tool and the job. A contractor writing customer copy with a chatbot needs to know it can invent facts.
- There is no official training certificate in Article 4. A dated note of who was shown what, including contractors, is a record you can show.
- A freelancer using AI only on their own unrelated clients, not on your behalf, is not your Article 4 person for that work.
- Will look for signs of AI use in the folders you choose, and write them down for you.
- Will write a plain-language readiness report. No evidence reads "Not assessed", never a green tick.
- Will run as a free Windows program on your own computer and send nothing from it.
- Coming with Guard: a check every month, kept so you can see your history and what changed since the last one.
- Coming with Guard: a printable readiness pack built from your check results — AI use found, training notes, disclosure checklist.
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Readiness guidance, not legal advice. The Free Toolkit sends nothing from your computer.