AI literacy plan
Northwind Talent GmbH, HRB 998877, Berlin
For the compliance owner and whoever delivers training; the completed records are the Article 4 evidence.
1. What Article 4 actually requires now
Art. 4 as amended by Reg. (EU) 2026/1744
Article 4 expects providers and deployers to ensure a sufficient level of AI literacy among the staff and other people dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training, and the context in which the systems will be used.
The obligation has applied since 2 February 2025, alongside the Article 5 prohibitions. It is not affected by the Chapter III deferral.
- Organisation
- Northwind Talent GmbH, HRB 998877, Berlin
- Plan owner
- Jana Novak — Head of People Operations, acting AI compliance owner
- Population in scope
- 51-250 people using AI tools at work
- Plan date
- 2026-09-11
- Refresh cycle
- Annual, plus on joining and on any material change in the tools used
2. Who needs to know what
Proportionality means different roles get different depth. At your size role-based tiers are worth the effort, because a blanket session pitched at everyone is pitched at nobody.
| Group | Needs to understand | Depth | Evidence |
|---|---|---|---|
| Everyone using AI tools | What the tools are, what must never be entered into them, that they remain responsible for the output, how to report a problem | One session of 45–60 minutes, plus the usage policy acknowledgement | Attendance record and signed acknowledgement |
| Managers and team leads | The above, plus how a general tool drifts into a high-risk use case, and that a named person takes decisions about people | The general session plus a 30-minute briefing | Attendance record |
| Anyone deploying customer-facing AI | Article 50 disclosure duties and the exact wordings we use | Walk-through of the disclosure kit | Sign-off in the disclosure implementation log |
| Assigned human overseers of high-risk systems | The system's limitations and failure modes, automation bias, when and how to override or stop it, and the logging duty | Structured training against the provider's instructions for use, with a competence check | Named competence record per Article 26(2) |
| Compliance owner | The classification framework, the register, the deadlines, and what changes trigger a reassessment | Ongoing — this kit, plus change alerts | This plan and the register |
3. Curriculum
- What the AI Act is and who it applies to — provider versus deployer, and why we can be both. Where we currently sit.
- The prohibitions: the eight practices under Article 5(1)(a) to (h), plus the two that apply from 2 December 2026. Framed as "never do this", with examples from our own work.
- Transparency in practice: what we must tell people, the wordings we use, and why claiming human review that did not happen is worse than no claim at all.
- Confidentiality and personal data: what must never be pasted into a tool, why data that leaves does not come back, and the approved-tools register.
- Judgement: hallucination, fluency as a risk signal, automation bias, and the rule that a named person takes any decision that affects a person.
- Reporting: what to report, to whom, and the assurance that prompt reporting is never itself misconduct.
- Role-specific module for overseers of the high-risk system: its limitations, its failure modes, and how to intervene.
Keep it concrete. The single most effective segment in this kind of training is five real examples from your own organisation — two where AI helped, two where it produced something confidently wrong, and one near-miss with confidential data.
4. Delivery and records
| Activity | Audience | Owner | Due | Completed | Record held |
|---|---|---|---|---|---|
| Induction session | All AI tool users | Jana Novak | [to be completed] | [to be completed] | [to be completed] |
| Usage policy acknowledgement | All staff in scope | Jana Novak | [to be completed] | [to be completed] | [to be completed] |
| Manager briefing | Managers and team leads | Jana Novak | [to be completed] | [to be completed] | [to be completed] |
| Overseer competence training | Named overseers | Jana Novak | [to be completed] | [to be completed] | [to be completed] |
| New joiner module | Joiners, within first month | Jana Novak | Ongoing | [to be completed] | [to be completed] |
| Annual refresh | All AI tool users | Jana Novak | [to be completed] | [to be completed] | [to be completed] |
Attendance record
Northwind Talent — AI literacy session Date: ____________ Delivered by: ______________________ Modules covered: ________________________________________ Name Role Signature ______________________ ______________________ ______________________ ______________________ ______________________ ______________________ ______________________ ______________________ ______________________
Plan owner
Approved by
Date
What a lawyer should check
Hand this list to counsel with the document. It is short on purpose — these are the points where a generated record most often diverges from the facts of a real organisation.
- Whether training obligations interact with works council or employee consultation requirements in your Member State.
- Whether the competence record for named overseers is specific enough to satisfy Article 26(2) for this particular system.
- Whether professional bodies in your sector impose their own AI competence requirements beyond Article 4.
- Whether any vendor contract already obliges you to train users in a particular way.
- This document is a structured record of an assessment you made, drafted for your review. It is not legal advice and it does not bind any authority.
- It reflects Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744 (the "Digital Omnibus on AI"), in force 27 July 2026. The Commission's guidelines on high-risk classification under Article 6(5) were due on 2 February 2026 and remain in draft (version of 19 May 2026), so classification positions that depend on them may change.
- No harmonised standard has yet been cited in the Official Journal, so the presumption of conformity in Article 40 is not available to anyone.