Article 4 is part of the EU AI Act's general framework, including for ordinary research and drafting tools. The AI Omnibus entered into force on 27 July 2026 and simplified its wording. Legal teams should assess the amended provision while maintaining practical training and supervision appropriate to their work.
What Article 4 requires after the amendment
The amended approach calls for measures supporting the development of AI literacy. It does not require a guaranteed level for each individual. The Commission and member states have a stronger supporting role. Check the amending regulation and the Commission's announcement for the current legal position.
Our suggested training records and review exercises below are practical governance recommendations. They are not a claim that Article 4 prescribes a particular course, certificate, number of training hours, or record format. Assess other professional and organisational requirements separately.
Identify the people and uses to support
Begin with the people operating or using AI on the organisation's behalf, including relevant contractors and secondees. Record which tasks they perform and which outputs they supervise. A partner approving a filing needs a different practical understanding from an operations manager evaluating a new service.
Ask each practice group for real examples. A generic training list can miss an unofficial workflow that staff already use. Keep the inventory connected to approved tasks and input restrictions so training addresses the tools and decisions people actually encounter.
Use the amended wording in the policy
The July amendment is in force. A policy should no longer describe Official Journal publication as pending or promise that training guarantees a specific level of competence for every person. Preserve the date and source behind the policy's legal analysis.
At the same time, avoid concluding that training is unnecessary. Professional competence, confidentiality, supervision, client instructions, and effective output review remain separate reasons to ensure that staff understand the tools they use. Have the responsible lawyer assess those duties in the relevant jurisdiction.
Build a practical programme for legal work
Use short exercises based on approved documents. For research, ask participants to locate an authority and check whether the passage supports the proposed proposition. For contract review, include an amendment or exception that a broad summary could miss. For drafting, require verification of facts, definitions, and source references.
| Role | Practical exercise | Review question |
|---|---|---|
| Research user | Verify a citation and its context | Does the source support the proposition? |
| Supervising lawyer | Review an output containing a known error | Would normal review detect it? |
| Procurement owner | Compare a claim with supplied evidence | What remains unverified? |
These exercises test whether the workflow is usable, not whether a participant can repeat a definition of AI. Adjust the programme when recurring mistakes show that source access, instructions, or escalation routes need improvement.
Assess consequences without inventing a penalty
Do not attach a generic AI Act fine to every training gap. Check the provision, applicable enforcement framework, national rules, and facts before describing a legal consequence. Equally, the absence of a dedicated training certificate does not establish that every other duty has been met.
Record incidents and near misses through the organisation's process. If a lawyer relies on an unsupported output, investigate the actual cause: missing source access, unclear instructions, inadequate review, or an unapproved use. A training attendance list alone does not explain whether the control worked.
Connect training to professional review
Teach users to distinguish retrieval from verification, extraction from interpretation, and a working draft from approved advice. Make the permitted use of confidential material clear before upload. Explain when a question belongs with local counsel, a qualified translator, or a technical expert.
Supervisors need enough time and evidence to perform their assigned checks. Avoid a nominal approval step that asks a reviewer to accept a polished paragraph without access to the underlying source.
Keep a useful evidence file
We recommend keeping the use inventory, role-based learning material, completion record, observed issues, and approved revisions together. Identify an owner and meaningful review triggers, such as new tasks, material service changes, or errors that existing instructions did not address.
Preserve earlier versions when the programme changes. A later reviewer should be able to see what staff were instructed to do at the time of a particular matter, rather than finding only a current policy with a refreshed date.
Use source-linked workflows for practice
Judicio's Legal Research, Document Review, and Drafting provide working material that legal teams can review against sources. Custom Workflows can support approved repeatable instructions.
The platform does not certify AI literacy or the organisation's compliance. Use a defined pilot and practical review exercises to assess the actual workflow. Our human review criteria guide and EU coverage page explain the related controls and source boundaries.