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EU AI Act Article 4 AI literacy record sheet for small businesses: who uses which AI tool, what they were shown, and when

Updated 23 Oct 2026 · Disclosure: the EURO AI Register mentioned below is an Unadhi product with a free edition. This guide is for information only, not legal advice.

What you get: a finished AI literacy record sheet: 10 columns, one row per person and AI tool (who, which tool for what, your role, what they already know, the risks, who the output affects, what they were shown, how, when and by whom, and the next refresh), each tied to Article 4 or the Commission's AI literacy Q&A, plus a made-up example row and an eight-line gap check. Made for small shops, agencies, clinics, trades and service businesses whose staff use chat assistants, writing tools, transcription or email helpers.

The short answer

Article 4 of the AI Act has applied since 2 February 2025. As replaced by Regulation (EU) 2026/1744 (the Digital Omnibus on AI), Article 4(1) says providers and deployers of AI systems shall take measures to support the development of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account their technical knowledge, experience, education and training, the context of use, and the persons on whom the systems are used. It does not require you to guarantee any specific level of AI literacy of any individual. Article 3(56) defines AI literacy as the skills, knowledge and understanding to make an informed deployment of AI systems and to gain awareness about the opportunities and risks of AI and possible harm it can cause.

The Commission's Q&A says no certificate is needed and organisations can keep an internal record of trainings and/or other guiding initiatives. National market surveillance authorities supervise and enforce Article 4 from 2 August 2026. A short record, one row per person and tool, is the practical way to show what you did.

The sheet (one row per person and AI tool)

ColumnFill inWhy
A. Person and role[Name or initials] · [role, e.g. front desk, bookkeeper] · staff / contractor / other on your behalfArticle 4(1): staff and other persons dealing with the operation and use of AI systems on your behalf
B. AI tool and what it is used for[Tool name, plan] · [the task, e.g. drafting customer replies]Q&A step a: what AI is used in our organisation?
C. Your role for this toolDeployer (you use someone else's tool) / provider (you build or brand it)Q&A step b: role of the organisation
D. What they already know[e.g. daily user, no AI training; or AI developer]Article 4(1): technical knowledge, experience, education and training
E. Risks for this tool and task[e.g. wrong answers, client personal data pasted in, output sent unchecked]Q&A step c: risks they need to be aware of; the Q&A gives hallucination as an example
F. People the output affects[customers, applicants, patients, none outside the business]Article 4(1): persons or groups on whom the AI systems are to be used
G. What they were shown[topics, e.g. checking facts, what never to paste in, when to ask a colleague]Q&A step d: build actions on the analysis above
H. HowBriefing / short course / written guide / supervised first use · link or file name of the materialNo fixed format; the Q&A says only relying on instructions for use may be ineffective
I. When and by whom[date] · [who gave it]Q&A: keep an internal record of trainings and/or other guiding initiatives
J. Next refresh[date] · or when the tool, the task or the person's role changesContext changes; the Q&A notes the speed of technological developments

Example row, made up: A. R.M., front desk, staff · B. Writing assistant, team plan, drafting replies to customer emails · C. Deployer · D. Uses it daily, no AI training · E. Confident wrong answers on prices and opening hours; customer details pasted in · F. Customers · G. Check every fact against the price list before sending; paste the question only, not the signature; ask the manager when unsure · H. 20-minute briefing plus the one-page staff AI rules (file: ai-rules-v2.pdf) · I. 23 Oct 2026, office manager · J. 23 Apr 2027, or when the tool or plan changes.

Eight-line gap check

If you findDo thisFixed
An AI tool in use with nobody on the sheet for itAdd a row for each person using it, including free accounts staff opened themselvesY / N
A contractor or freelancer uses AI on your workAdd them in column A; agree what they need to knowY / N
Column E is emptyWrite the two or three things that could go wrong with this tool and taskY / N
Column G says only 'read the manual'Add a short briefing or supervised first use, matched to columns D and EY / N
Output goes to customers or decides something about peopleCover checking and escalation in G; if the use may be high-risk, read the Article 26 human oversight dutyY / N
No date or name in column IFill it from memory now, then keep it currentY / N
Tool, plan or task changed since column IBrief again and update the rowY / N
No next date in column JSet one and put it in the diaryY / N

Do this week

This sheet is a working aid, not a legal opinion or proof of compliance. References are to Regulation (EU) 2024/1689 (Articles 3(56) and 4) as amended by Regulation (EU) 2026/1744, and to the Commission's AI literacy Q&A as read on 23 October 2026. The Q&A also notes that the Commission will publish practical examples of how to comply, and that the AI Board will adopt recommendations; check the official sources for updates. Deployers of high-risk AI systems have a separate human oversight duty in Article 26. Spot an error in this guide? Write to mininglife7@gmail.com.

For accountants and tax advisers

If you look after small business clients, this is a one-page sheet you can hand them next to their client AI inventory, and you can fill it for your own practice too. Stay inside your professional rules and refer legal questions on.

Keep each row next to your AI register

The EURO AI Register free edition runs in your browser with no account and no upload. It covers your first 10 AI systems and 10 evidence records, the screening questions, duties by role with dates, and a printable Article 4 AI-literacy record. List each AI tool once, and keep each briefing as an evidence record.

When you need more than 10 systems, the EURO AI Register membership starts at $19 a month and adds unlimited systems, rule updates and email help. Neither tool is legal advice or proof of compliance.

Partner programme opening soon

Partner programme opening soon: join the free waitlist. Planned terms are 50% of each referred sale (75% once you have 5+ paying customers), single level, paid through Gumroad only from revenue received.

Free start: list your AI tools in the EURO AI Register free edition, then fill one row per person. Related: Article 4 AI literacy explained · AI literacy for small businesses · staff AI use policy · privacy-by-default settings sheet · AI vendor questions.

Sources

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Unadhi Guides are free, independent explainers. We correct errors as soon as we find them: write to mininglife7@gmail.com.