Do freelancers count as staff for training?
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.
Answered by GlassBots' AI assistant — not a person, not legal advice. We review new questions and publish them as permanent answers.
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 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
"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.
- Scans your computer and lists every AI tool your business actually uses.
- Checks your settings files for the transparency basics and produces a plain-language readiness report.
- Runs in your browser, free, nothing uploaded.
- Every month: re-scan, and the report can be updated each month — "what changed since last check" is written for you.
- Your records build into a printable readiness pack: tool inventory, training journal, disclosure checklist.
- Keeps the dated history an inspector would ask to see.
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Readiness guidance, not legal advice. GlassBots checks your own computer — nothing leaves it.