Policies & templates
Article 4 training plan template
A one-page training plan you can adapt to satisfy Article 4 of the EU AI Act. It covers scope (who needs training), content (what is covered), cadence (how often), and evidence (where it is recorded). Placeholders use the {{TOKEN}} syntax — search-and-replace before circulating.
Download as markdown · Legal advice it is not — review with your own counsel before adopting.
Template
The text below is the template. Copy it into your own document, replace each
{{TOKEN}}, and adjust the language to fit your company’s voice.
{{ORG_NAME}} — Article 4 AI Literacy Training Plan
Effective date: {{EFFECTIVE_DATE}} Owner: {{TRAINING_OWNER_NAME}}, {{TRAINING_OWNER_TITLE}} Review cadence: {{REVIEW_CADENCE}} (e.g., annually)
Purpose
This document describes how {{ORG_NAME}} satisfies Article 4 of Regulation (EU) 2024/1689 (the EU AI Act), which requires that staff who use AI systems have a sufficient level of AI literacy. The plan is a living document — it is adjusted as the company’s tool stack and team evolve.
Scope (who needs training)
The training applies to:
- All employees and contractors who use AI tools or AI-enabled features in the course of their work at {{ORG_NAME}}.
- Specifically, anyone listed as a user of any tool with status “Approved” in {{REGISTER_LOCATION}}.
The training does not apply to staff who do not interact with AI tools. The list is reviewed every {{LIST_REVIEW_CADENCE}}.
Content (what is covered)
The training covers, at minimum:
- What an AI system is in the legal sense (Regulation (EU) 2024/1689 definition) and how that maps to the tools the company uses.
- Risks specific to AI tool usage at {{ORG_NAME}} — data leakage, hallucination, biased output, prompt injection, IP exposure.
- The company’s AI Usage Policy — approved tools, data classification rules, when to escalate.
- Article 4 — what it requires, why we record this training, what evidence looks like.
- Practical guardrails — what staff should and should not do with company data inside AI tools.
- Reporting — how to flag misuse or unexpected behaviour.
Training materials are stored in {{TRAINING_MATERIAL_LOCATION}}. Versions are dated and prior versions retained for audit traceability.
Cadence (how often)
- Initial training — within {{INITIAL_TRAINING_WINDOW}} (e.g., 30 days) of an employee starting AI tool usage.
- Refresher — every {{REFRESHER_CADENCE}} (e.g., 12 months) for all in-scope staff.
- Material-change retraining — if the AI Usage Policy or the approved tool list changes materially, in-scope staff complete an abbreviated retraining within {{MATERIAL_CHANGE_WINDOW}}.
Delivery format
{{DELIVERY_FORMAT}} (e.g., “30-minute live session led by {{TRAINING_OWNER_NAME}}, recorded for asynchronous viewing; quiz at the end with a passing score of 80%.”)
Evidence (where it is recorded)
Each training event and each individual completion is recorded in {{TRAINING_LOCATION}} (e.g., “AIRegistra → Training”). Evidence captured includes:
- Training session date, duration, content version.
- Attendee list (employee, completion date, score).
- Materials used (links to {{TRAINING_MATERIAL_LOCATION}}).
- Trainer identity.
This evidence is referenced from the EU AI Act readiness checklist in {{READINESS_LOCATION}} as proof for Article 4 obligations.
Roles and responsibilities
- {{TRAINING_OWNER_NAME}}, {{TRAINING_OWNER_TITLE}} — owns the plan, schedules sessions, maintains materials.
- {{COMPLIANCE_OWNER_NAME}}, {{COMPLIANCE_OWNER_TITLE}} — owns Article 4 readiness; reviews evidence quarterly.
- People managers — ensure their direct reports complete training within the windows above.
Review and updates
This plan is reviewed every {{REVIEW_CADENCE}} by {{TRAINING_OWNER_NAME}} together with {{COMPLIANCE_OWNER_NAME}}. Material updates are versioned, dated, and communicated to all in-scope staff.
This template is provided by AIRegistra (Mindysm OÜ, Tallinn, Estonia) as a starting point. It is general guidance, not legal advice — review with your own counsel before adoption.
4 min read · Last updated