Is copying a practice from the Commission's living repository enough to comply with Article 4?
No. The Commission states that replicating the practices in its living repository does not automatically grant presumption of compliance with Article 4. The repository is a source of ideas from AI Pact signatories and other organisations; the duty is still to calibrate measures to your own systems, people and context, and to record that judgement. Copied as a template, it produces a programme designed for someone else's organisation.
What the living repository is
The EU AI Office published a living repository of AI literacy practices in early 2025, gathered first from signatories of the AI Pact and later from other organisations, and has since revamped it to make the practices easier to search. The Commission's Q&A describes it as providing examples of more than 40 AI literacy initiatives from companies and the public sector, from e-learning platforms and in-person training to bootcamps and collaborations between industry and academia. You can filter practices by how far along they are: planned, partially rolled out or fully implemented.
Myth: if a practice is in the repository, the Commission has approved it
The Commission's page on the repository says that while replicating the practices collected there does not automatically grant presumption of compliance with Article 4, the repository aims to encourage learning and exchange. The Commission also says it will draw on the repository for the compliance examples the amended Article 4(2) requires it to publish on the Single Information Platform. Those examples have not been published yet. Until they are, inclusion is not endorsement, and it is not a finding that the practice met Article 4 for the organisation that submitted it, let alone for yours.
Myth: a bigger organisation's programme is a safe one to copy
Most of the submissions come from large companies and public bodies with training teams. Their programmes are built for their tools, their roles and their risk profile. A bank's three-tier curriculum for model risk staff is not what a forty-person recruitment agency needs, and adopting it would fail the Commission's fourth step, which is to build your literacy actions on an analysis of your own organisation's role, its systems and their risks.
How to use the repository well
- Read it for shapes, not content. Notice which organisations split their programme by role, which ones used short scenario sessions, which ones paired training with a policy.
- Steal the format that fits your size, then fill it with your own inventory.
- Write down why you chose that shape for your people. That note is the calibration, and it is the part of the record a regulator would read first.
The four steps the Commission sets out, and how each workshop tier covers them, are on our requirements page.
Sources
- European Commission, living repository to foster learning and exchange on AI literacy, for the presumption-of-compliance passage and the AI Pact origin.
- European Commission, AI literacy: questions and answers, for the description of the repository and the four-step approach.
- Regulation (EU) 2024/1689, the AI Act, Article 4, as amended by Regulation (EU) 2026/1744.
This is general information about the EU AI Act, not legal advice. Enforcement is proportionate and case by case, and your sectoral regulator may issue guidance that applies to you.
