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.

A practical evidence set

If a market surveillance authority asks about your AI literacy measures, these records help explain your approach:

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.