Not your policy document and not your attendance list. Three questions you can answer in an afternoon, or can't.
Enforcement of Article 4 started this month and the first reflex is to write a policy document. Understandable, and rarely what gets asked first. What gets asked is more concrete and shorter, and precisely for that reason harder to answer with what most organisations have on hand.
Question one: which AI do you use?
Sounds easy. The official list holds Copilot and perhaps a translation service. The real list also holds the free accounts people set up themselves, the AI feature quietly switched on in an existing package last year, and the plug-in someone in marketing found handy. Anyone submitting only the first list gets the second back as a follow-up.
Question two: who does what with it?
Here it gets interesting, because this is the question 'everyone did the training' doesn't answer. Article 4 asks for a level appropriate to role, context and risk. A communications adviser having a press release sharpened is somewhere else entirely than someone summarising an objection. Without a distinction per role you have no case, only an offering.
Question three: how do you know it helped?
This is where nearly everyone gets stuck, and it's also the fairest question. An attendance list proves attendance. A feedback form proves satisfaction. Neither says whether anyone works differently. The only answer that holds is the same measurement twice, with the dates on it.
What this means in practice
- Start with the inventory, not with buying a training.
- Ask the teams and not only IT: the shadow list sits with the users.
- Measure before you train, even if that costs a week. You can't measure a baseline afterwards.
- Set a date for the repeat straight away. Without it your file expires.
And the nuance that goes with it: the chance a regulator knocks on a Copilot rollout in the first year is small. The early years of a new regulation address high-risk applications. These three questions simply arrive sooner in a tender, during an audit or from the works council, and they're pressed just as hard there.