Art. 4 AI literacy training: ready programme + required documentation

“What is ChatGPT” does not meet Art. 4

Recall the core from Tuesday’s article: the rule demands competence proportionate to roles and context and — in evidentiary practice — documentation. A one-off webinar for everyone meets neither: it does not differentiate scope (HR with a recruiting tool needs something else than reception), leaves no register, has no update cycle. The programme below is designed backwards from those three requirements.

Three modules — the full syllabus

Module 1 · AI basics and limits (60–90 min)

• How language models work — at the level needed for safe work, not a maths lecture.
• Hallucinations as an architecture feature, not a bug: when you may trust a model, and when every number needs a source.
• Data: what never goes into public tools (personal data, confidential info, code, contracts) — with leak examples.
• Practice on the tools the company actually uses — not abstract demos.

Module 2 · Regulation and duties (60–90 min)

• Operational AI Act: bans (Art. 5), AI literacy (Art. 4), transparency (Art. 50) — who in the firm owns what.
• GDPR × AI: processing bases, Art. 22 for automated decisions (recruitment, scoring).
• Civil liability after PLD: why this training’s documentation is due-diligence evidence.
• For high-risk groups (HR, finance): bias, human oversight, right to human review.

Module 3 · Company policy and safe use (60–90 min)

• Company AI policy: allowed tools, banned tools, process for proposing new ones — working from a one-page template.
• Shadow AI: why bans fail and how to build safe alternatives instead of an underground.
• Labelling AI content in team practice (content, support) — aligned with Art. 50.
• Escalation path: what to do when AI is wrong, when a client asks, when something leaks.

Four formats — and when to use which

Who, what, how much — proportionality in one table

Documentation you must produce

This is the part 90% of training offers skip — and which makes the entire evidentiary difference. After the programme, five documents should be in the file:

1. Training programme with role-based scope rationale (directly answers the rule’s “proportionality”).
2. Role matrix — who, what scope, why.
3. Participant register with dates and completions.
4. Certificates for participants (or e-learning completion export).
5. Update schedule — review every 6–12 months + onboarding module, calendarised with an owner.

Templates for all five documents are free — for self-use:

What it costs — and who may pay for it

For a 50–150 person firm a full pack (e-learning for all + workshop for 2 groups + board briefing + documentation) usually lands in the low tens of thousands of PLN — below the cost of one day of legal dispute. Two external funding paths:

• National training funds (e.g. KFS in Poland): employers can get training co-funding — up to 80%, micro-enterprises up to 100% of costs 2026 priorities to verify. Apply via the local labour office; we help prepare the justification.
• Digital transformation grants (DIG.IT and related) — AI training as part of a larger project. We cover this more broadly in an upcoming article on funding compliance.

Exactly what you get in the pack

• An agenda fitted to your tools and roles (not a generic syllabus) — after a short intake interview.
• Participant materials + a one-page AI policy template ready to roll out on Monday.
• Full evidence document pack: programme, matrix, register, certificates, schedule — ready for an authority or client question.
• Art. 4 compliance report with next-step recommendations (Art. 50, inventory, policy).
• 6-month follow-up: material update for regulatory changes and a cycle reminder.

FAQ

Common questions

Online or onsite?

Both. Workshops work well live online (up to 15 people); board briefings are best onsite — in our experience: a conversation about personal liability needs a room, not cameras.

How many people per workshop?

Up to 15 — above that we split groups. The workshop runs on your real cases; at 30 people it becomes a lecture, i.e. the webinar this article started by rejecting.

Can we make 2 August?

Yes, if you decide by the preceding Wednesday. And if you miss it — on 3 August the duty does not vanish; only the date on your training register grows in value.

Does this cover the whole AI Act?

No — and do not trust anyone who claims otherwise. Art. 4 is the foundation and the cheapest due-diligence evidence. Beside it sit Art. 50 labelling, system inventory and AI policy — all covered in this series.

This article is informational and is not legal advice. Prices are indicative (net) and may depend on scope; verify training-fund/grant conditions in current calls.