How to document AI training for employees without building an LMS

The LMS myth

Many companies think they need a learning management system to prove AI literacy under Article 4. They don't.

The Commission's Article 4 FAQ is clear: internal records of trainings are sufficient documentation. There is no mandated format. No platform requirement. No certification body.

What you actually need

Three documents:

1. Training record log

A spreadsheet with these columns:

• Name
• Role
• Training module
• Date completed
• Format (live session, recorded video, self-paced)
• Trainer or source
• Refresher due date

That's it. You can build this in Google Sheets or Excel in 10 minutes.

2. AI-use policy

A document covering:

• Which AI tools are approved
• What data can and cannot be entered into AI tools
• How to review AI output before using it
• How to report AI-related incidents
• Review cadence (e.g., annual)

4-6 pages is enough for most SMEs.

3. Training materials

Keep copies of the slides, handouts, or videos used. You don't need to produce a polished course — a slide deck presented in a team meeting counts.

How to deliver training without an LMS

• Live session: Present a slide deck in a team meeting. Log attendance.
• Recorded: Record the session and share it with absent staff. Log who watched.
• Self-paced: Share the slides and policy. Ask staff to confirm they've read them. Log the confirmation.

All three formats are valid. The key is the record, not the platform.

What an auditor would ask for

If a market surveillance authority asks about your AI literacy measures, they would want to see:

1. Who was trained and when (your record log)
2. What was covered (your training materials)
3. That training is role-aware (different content for different roles)
4. That you have a policy (your AI-use policy)
5. That you plan to keep it current (refresher dates)

None of this requires an LMS.