Article 4 has applied since February 2025, but national authorities start supervising and enforcing it on 2 August 2026. The evidence they ask for is not a policy document — it is a dated, role-mapped record of who was trained, on what, and when. Most marketing teams have a Slack thread and a signed acknowledgement.
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The Digital Omnibus softened Article 4 from an obligation of result to one of effort — but it did not move the date. That makes the documentation itself the test. This app produces the artefact, not another training course.
Article 4 covers "other persons dealing with the operation and use of AI systems" for you — so freelancers, contractors and agency partners are in scope and flagged separately, because they are the population no HR system tracks.
Nineteen role types map to Tier 1 Aware, Tier 2 Operator or Tier 3 Configurer/Procurer, raised automatically for anyone who configures tools or runs client data through them. Override any assignment and the reason is recorded — a considered judgement is itself evidence.
Four explicit flags: nobody with no record at all, anyone whose logged training falls short of their tier, overdue or stale records, and every external partner listed on their own. With a documented-versus-undocumented headline number.
Register table, per-person sheets, coverage-by-tier summary and an editable measures-taken statement, laid out as one clean dated document. Print it or save it as a PDF and the file is your answer to the question.
A five-person team, two of them external. The gaps sort themselves.
| Name | Type | Required | Covered | Last trained | Status |
|---|---|---|---|---|---|
| Dana WhitfieldContent writer | Staff | Tier 2 | Tier 2 | 27 Apr 2026 | Current |
| Marcus ReillyMarketing ops / martech | Staff | Tier 3 | Tier 1 | 26 Jun 2025 | Overdue |
| Priya NandakumarDesigner / creative | Freelancer | Tier 2 | None | — | Never recorded |
| Tom AldertonExecutive / leadership | Staff | Tier 1 | Tier 1 | 24 Sep 2025 | Due soon |
| Sable CreativePaid media / PPC | Agency partner | Tier 2 | Tier 2 | 3 Mar 2026 | Review required |
The market's answer to Article 4 is an annual per-seat LMS contract that takes weeks to roll out, or a blank template with no logic in it. There is no mandated template and nothing in between. This is the in-between: $19, once, and you have the register by the end of the afternoon.
Buy it, open it, fill it in. No account, no subscription, no seat count.
Possibly. Article 3(4) makes anyone using an AI system in a professional context a deployer, and the Act reaches non-EU deployers whose AI output is used in the Union — so a US agency with one European client is inside the perimeter. Even where it isn't, the register is the same artefact a client's procurement team asks for.
No, and that's the point. It is the record-keeping half that the courses don't give you. Log whatever training you already do — a live session, a written brief, a vendor course — and the app turns it into a dated, role-mapped, printable register.
Nowhere. It is a single HTML file that stores everything in your own browser. You are typing in staff names and tool usage, so that matters. Export a JSON backup or CSV whenever you want a copy.
No. It is a record-keeping aid. The tiers it suggests are a practical starting point you are expected to review and adjust, and the app says so on every screen and in the printed pack.