Does the AI training obligation also cover temporary staff, freelancers and apprentices?

Yes, all three groups, as soon as they work with the company’s AI systems. Article 4 of the AI Act requires measures to promote AI literacy not only for a company’s own staff, but explicitly also for other persons who deal with the operation and use of AI systems on the deployer’s behalf. The employment contract is irrelevant to this.

This is where most records turn out to have holes. A company trains its 80 permanent office staff, documents it properly, and overlooks the four agency workers in production who operate an AI-assisted quality check every day, along with the freelance copywriter who drafts product descriptions with a language model.

This article sets out who falls within the wording, what the assignment looks like in practice for external staff, and how the record for it comes about.

Who falls within the wording of Article 4?

Persons who deal with the operation and use of AI systems on the company’s behalf. The provision has applied since 2 February 2025 and turns on actual involvement. Agency workers, contractors, freelancers, interns and apprentices are therefore covered, provided they operate one of the company’s AI systems or work on with its outputs.

Conversely, anyone who touches no AI system is not covered, even on a permanent contract. A first-year apprentice working solely in goods receiving is out of scope. An apprentice in marketing who uses an image generator for social media drafts is in scope.

For apprentices a second reason applies that has nothing to do with the AI Act. The training company owes the transmission of occupational skills, and in commercial as well as technical trades handling AI tools now forms part of that. Here the training is part of what the company owes as a trainer, not merely compliance.

How do I handle freelancers and service providers who bring their own tools?

This is where responsibility divides. Anyone self-employed who uses only their own AI tool on their own infrastructure and delivers just the result to the client is responsible for their own AI literacy. They are then a deployer in their own right under the regulation.

As soon as the company provides access, however, meaning an account in its Microsoft 365 tenant, a licence for one of its systems or access to an internal assistant, that person is dealing with the operation of the system on the company’s behalf. They then belong in the assignment.

For procurement and legal this means the question belongs in the contract. Two variants work. Either the service provider evidences their own AI literacy in a verifiable way, or they are trained through the company’s learning platform like internal staff. The in-between state, where nobody feels responsible, is the expensive one.

With temporary work through a staffing agency, experience shows that the agencies do not supply AI literacy along with the placement. Waiting for that is likely a long wait. Assigning a learning path takes less time than negotiating who owes it.

What does a record for Article 4 and Article 50 have to deliver in practice?

It has to show which roles are involved with AI, that these people were trained, and when the next review takes place. The Digital Omnibus turned Article 4 into an obligation to take measures and to evidence them; the provision does not carry a fine of its own. Anyone who has to give an account is asked about the assignment, not about the number of certificates.

For external staff the assignment is in fact the more important part. A list naming four agency workers and one freelance copywriter as AI-involved, with documented training for them, carries more weight than 80 certificates with no assignment at all.

Article 50 comes on top for some of these people because it carries different duties. Since 2 August 2026 a deployer has to label AI-generated content that goes out externally and to disclose deepfakes visibly. The freelance copywriter and the marketing apprentice therefore need not only general AI literacy but the concrete knowledge of when a text or an image they produced requires labelling. How that duty works in detail is set out in Do I have to label my website chatbot as AI?.

Is there a recognised certificate for external staff?

There is no state accreditation for AI training at all, neither for permanent nor for external staff. Anyone advertising “state-recognised” means something else, usually a provider approval for subsidised measures, which has nothing to do with the AI literacy obligation. What holds up is a record that is personalised, rests on a real assessment and matches the actual use of AI in content. The longer treatment is in Which AI certificate is genuinely recognised?.

With external staff a practical requirement is added that rarely shows up with permanent employees. The record has to outlast the person who leaves the company again. An agency worker is gone after four months, but the documentation of their training has to stay with the company rather than sitting in their personal inbox. A certificate held only by the individual is of no help to the company at the next review.

What the AI licence at 59 euros covers

The AI module of the PASSION4IT Academy costs 59 euros per user per year and includes the AI licence for the duties under Article 4 and Article 50. Access runs twelve months from the activation date, every completed training yields a certificate, and the progress view supplies the per-person record of participation. Trainings run in units of 20 to 30 minutes at the workplace, with no seminar day.

For external staff the billing is the real advantage. The licence is booked per user, there is no minimum quantity, and users can be imported by CSV. An agency worker coming in for four months gets a licence like anyone else. Adding Cyber Security and Digital Work puts you at 99 euros per user per year with the Business Bundle instead of 137 euros booked separately.

One point stays manual. With external staff the company decides who assigns the learning path and who follows up. With temporary work that is usually production management rather than HR, because that is where it is known which machine the person is working on.

Conclusion

The obligation follows usage. Anyone operating an AI system on the company’s behalf belongs in the assignment, regardless of who pays the salary. For agency workers and apprentices, assigning a learning path is the shorter route than clarifying responsibility; for freelancers with their own tools the question belongs in the contract.

To sort this out for your own company, take the list of external people currently on site and mark who touches one of your systems. In most companies with 100 to 300 employees that is between three and fifteen people, and they appear in no training plan.