EU AI Act Article 4 checklist

The 5-step Article 4 checklist

If your team uses AI tools at work — ChatGPT, Copilot, Claude, or any other — Article 4 of the EU AI Act requires you to ensure a sufficient level of AI literacy. Here's a checklist you can complete in one afternoon.

Step 1: List the AI tools your team uses

Identify every AI system your staff interact with. Include consumer tools (ChatGPT, Claude, Copilot), embedded AI in software you already use, and any custom or internal AI tools. Don't forget contractors and interns.

Step 2: Write an AI-use policy

Create a written policy covering approved tools, prohibited uses, data handling rules, output review expectations, and incident reporting. 4–6 pages is enough for most SMEs.

Step 3: Train employees

Deliver role-based training covering AI risks, limitations, hallucinations, privacy, and human review. At minimum: one general session for all staff, plus add-on modules for roles with specific risks (HR, marketing, developers).

Step 4: Keep an internal record of training or guidance

Log who was trained, when, what was covered, and the format. A spreadsheet is sufficient — no LMS required. The Commission confirms there is no need for a certificate.

Step 5: Review the policy when tools or guidance change

Set a refresher date for each person. Review your policy and training materials annually, or when new tools are introduced or guidance changes.

What you don't need

• No certificate or accreditation
• No external training provider
• No learning management system
• No specific number of training hours
• No submission to any authority

Free template

Download the free AI training record log to get started with step 4. It's a spreadsheet with columns for name, role, module, date, format, trainer, and refresher due date.