Is there a specific fine for failing to train staff on AI?

Article 99 of Regulation (EU) 2024/1689 assigns Article 4 no dedicated EU penalty tier, unlike prohibited practices or transparency duties. That does not make the obligation voluntary or immune from sanction: the Commission says national market-surveillance authorities may impose penalties or other measures under national law. The duty is real, but it is not a duty to buy a particular course.

What Article 4 actually requires

Article 4 of the AI Act, applicable since 2 February 2025, requires providers and deployers to take measures supporting the development of AI literacy among their staff and other persons operating or using systems on their behalf. The measures must account for their knowledge, experience, education, training and context of use. It requires no guaranteed individual level and mandates no particular course, hours, exam or certificate.

Which breaches do carry fines under Article 99

Article 99 sets out an exhaustive list of fineable breaches and their amounts. This is the complete list:

• Article 5, prohibited AI practices: up to 35 million euro or 7 % of worldwide annual turnover, whichever is higher.
• Articles 16, 22, 23, 24, 26, 31, 33 and 34, obligations of providers, authorised representatives, importers, distributors, deployers and notified bodies: up to 15 million or 3 %.
• Article 50, transparency obligations, including disclosing that a person is interacting with an AI: up to 15 million or 3 %.
• Incorrect, incomplete or misleading information supplied to authorities: up to 7.5 million or 1 %.

Article 4 appears in none of those EU penalty tiers. For SMEs and startups the Regulation also takes the lower of the fixed amount and the percentage, not the higher. The absence of its own tier does not prevent a national authority applying penalties or measures available under national law.

So why do so many pages claim there are fines for not training

Because training sells better with a number next to it. Search results are full of consultancy and training-provider pages citing severe fines without naming an article or an amount, and others attributing the 15 million of Article 99(4) to Article 4. Neither holds up against the text. It is a clear case of content copied between sites without going back to the source.

What can actually happen without AI literacy

The absence of a dedicated Article 99 tier does not mean there are no consequences. The first and often most immediate is commercial: AI literacy appears in enterprise procurement questionnaires, so its absence can block contracts. Publicly, national market-surveillance authorities may request information, order corrective measures and impose sanctions available under national law. Enforcement must be proportionate to the case, and an incident caused by inadequate training or guidance can increase the likelihood of intervention.

What is still undecided in Spain

The Spanish penalty regime is not settled yet. The Organic Law Bill on the good use and governance of artificial intelligence was approved by the Council of Ministers on 26 May 2026 and published in the Official Bulletin of the Cortes Generales on 12 June 2026, with an amendment period running to 30 June. It remains in parliamentary process and, as an organic law, requires an absolute majority in Congress. Until it passes, any claim about specific penalty amounts in Spain is anticipating a text that can still change.

What to do about it

Taking AI-literacy measures remains mandatory and worthwhile for the right reason: because it is required and because clients will ask about it in vendor reviews. Training can be an appropriate measure, but the Regulation does not require buying a particular course. Nor is there any need to purchase one in haste over a fine the Regulation does not attach directly to Article 4.