What record should we keep to show we met Article 4?
Keep an internal record of the training and guidance you provided: what was covered, who attended, when, and why that depth suited those roles in your context. The European Commission's Q&A on AI literacy says there is no need for a certificate and that organisations can keep an internal record of trainings and other guiding initiatives. There is no prescribed form, so the record can be a single document as long as it answers those questions.
The five things the record should contain
- The inventory. Which AI systems are in use, including features bundled inside software you already bought, and which roles use each one.
- The measure. What training or guidance was delivered, in what format, and by whom.
- The attendance. Who took part, by name and role, with the date.
- The calibration. A short note on why that depth suited those people. A team that writes emails with a chatbot needs a different session from a team that configures a screening tool.
- The review date. When you intend to look at it again, and who owns that.
What the record does not need
It does not need test scores, because there is no obligation to test. It does not need a certificate, because the Commission says none is required. It does not need to prove that any individual reached a particular level, because the July 2026 rewrite removed that idea from the article.
A worked example
A forty-person professional services firm runs a half-day session for everyone, then a ninety-minute follow-up for the three people who administer the CRM's AI features. The record is two pages: the inventory, a paragraph on each session, two attendance lists, and a line explaining why the CRM administrators got extra depth. That is a documented measure.
Every tier of our workshops leaves you with this record written, not as a template to fill in afterwards.
Sources
- European Commission, AI literacy: questions and answers, the answer on documentation and certificates.
- Regulation (EU) 2026/1744, the Digital Omnibus on AI.
This is general information about the EU AI Act, not legal advice. Enforcement is proportionate and case by case, and your sectoral regulator may issue guidance that applies to you.
