Does using ChatGPT at work fall under Article 4?
In general, yes. The AI Act defines a deployer as anyone using an AI system under their authority, except for personal non-professional activity (Article 3(4)). When your staff use ChatGPT for work tasks, your organisation is using an AI system under its authority, so Article 4 applies to that use.
What that means in practice
Using ChatGPT for emails or translations is not high-risk in itself. The main literacy topics are the tool’s limits — it can invent facts — and what information must not be entered.
Personal accounts are a common gap
Employees often use free personal accounts for work. Decide whether that is allowed, and if not, provide an approved tool. This is also a data-protection question under the GDPR.
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