Sector
AI Act training for Irish credit unions.
A credit union whose staff or volunteers use AI at work is a deployer under the EU AI Act. That includes AI features built into lending, member service and office software. Article 4 requires the credit union to take measures that support AI literacy among its staff and the other people who use AI on its behalf.
Karv Training delivers that measure as a live workshop and leaves the credit union with a dated, signed record of what was done.
Written by Danny McCabe, QQI Level 6 Certificate in Training Delivery and Evaluation
What does the AI Act ask of a credit union?
Under Article 4 of the EU AI Act, as amended by Regulation (EU) 2026/1744 in July 2026, a credit union must take measures to support the development of AI literacy among its staff and the other people who operate or use AI systems on its behalf. The measures are calibrated to the tools in use, the people using them and the context. The article states that it does not require you to guarantee any specific level of AI literacy of any individual.
Article 4 has applied since 2 February 2025, and national authorities have supervised the AI Act since 2 August 2026. The European Commission's Q&A says no certificate is required and that an organisation can keep an internal record of training and guidance. It also says Article 4 carries no obligation to measure what employees know.
Article 4 carries no fine of its own, under Article 99 of the AI Act or under Ireland's Regulation of Artificial Intelligence Act 2026. The Central Bank of Ireland is designated as a market surveillance authority under the AI Act for financial services, and it already regulates credit unions, including through fitness and probity. Its Regulatory and Supervisory Outlook 2026 says that "technical competence and ethical behaviour are required from those using the tools".
Who in a credit union needs to be covered?
Everyone who uses an AI system on the credit union's behalf, whether or not they are paid. Article 4 names staff and other persons dealing with the operation and use of AI systems on your behalf, so the test is what a person does with the tools, and volunteers are inside it.
- Member services and tellers
- Drafting replies, summarising calls and working alongside a website chatbot.
- Loan officers and the credit committee
- Relying on affordability or credit scores produced by the lending platform.
- Compliance, risk and internal audit
- Reviewing transaction monitoring flags and answering for how the tools are governed.
- Managers and marketing
- Writing reports, policies and member communications with a general-purpose assistant.
- Volunteer directors and the board oversight committee
- Using AI to prepare or summarise board papers, and overseeing how the credit union uses it.
- Contractors and outsourced IT
- People who configure or support your systems and are not on the payroll.
A director who never opens an AI tool still sits on the board that answers for the ones in use. We recommend including the board in the session for that reason, and the record lists each attendee by role.
Is credit scoring high-risk under the AI Act?
Yes, where AI does the scoring. Annex III point 5(b) of the AI Act lists AI systems used to evaluate the creditworthiness of natural persons or establish their credit score as high-risk. AI systems used to detect financial fraud are excepted.
The Digital Omnibus moved the application date for most Annex III obligations to 2 December 2027. From then, Article 26 requires a deployer to assign human oversight of a high-risk system to people who have the necessary competence, training and authority. In a credit union those people are the loan officers and credit committee members who rely on a score when they decide on a member's loan. Under Article 111(2), a system that was already in service before that date is only brought in once its design changes significantly.
Whether your lending platform is caught depends on what the scoring feature does, and the answer usually sits with your software provider. The tool inventory we complete with you before the session records each system, what it is used for and who uses it, so you know what to ask them.
Article 4 does not wait for December 2027. It applies now to the people using those tools.
What can your board show for it?
A dated record, signed by the trainer who delivered the session. Since the July 2026 amendment the question under Article 4 is what measures your credit union took, and the record is how you answer it when the board, your auditor or the Central Bank asks.
The record has five parts
- Inventory
- The AI systems in use and the roles that use them.
- Measure
- What was delivered, in what format and by whom.
- Attendance
- Who took part, by name and role, with time attended.
- Calibration
- Why that depth suited those people in your context.
- Review
- A recommended review date and a named owner.
Organisational training record
1. Inventory
| System | Used for | Roles |
|---|---|---|
| Microsoft 365 Copilot | Drafting, summarising, meeting notes | All staff |
| Loan origination platform, automated affordability scoring | Credit decision support | Lending team, credit committee |
| Member services chatbot on the website | First-line member queries | Member services |
| Transaction monitoring, anomaly flags | Fraud and AML screening | Compliance |
Each attendee also receives a Certificate of Attendance. It acknowledges that the person attended and points back to the record. It is not a qualification and it is not evidence of compliance on its own.
What does the session look like?
We suggest starting with the half day. It runs for three and a half hours, live, online or in person at your office, for everyone who uses an AI tool.
It covers what AI is and where it fails, the tools your credit union runs, the risks that go with each role, and Article 4 as it stands after the Digital Omnibus. The examples come from credit union work: a member's details pasted into a chatbot, a score nobody at the counter can explain, a website assistant that does not say it is one.
Where the lending team or the credit committee relies on scoring, the full day adds depth for those roles and a first draft of an AI acceptable-use policy.
Half day
€2,250
ex VAT, flat rate for up to 25 people. Staff and volunteers count the same.
- Training record
- Tool inventory
- Attendance log
- Recommended review date
- Full day and two day workshops are quoted on a 20-minute call.
- Board briefings are available on request.
- In-person delivery is based in County Louth. Travel outside the county is charged at cost.
Who delivers it?
Three trainers. Danny McCabe leads online delivery, and Padraig McCabe and John Leech deliver in person anywhere in Ireland.
Danny McCabe
Trainer, online delivery
Danny has trained over 600 professionals across productivity, Agile, management and education, and runs a web studio where AI sits at the centre of the work: campaigns, ads, content and the tools behind them. He holds a QQI Level 6 Certificate in Training Delivery and Evaluation and a postgraduate diploma in education, and leads Karv Training's online delivery.
Padraig McCabe
Trainer, in-person delivery
Padraig has 39 years of global business experience, managing projects and delivering executive training in 58 countries and 32 US states. A company owner since 2005, he has held CEO and C-suite roles across procurement, business development, operational excellence and change management, and is a Lean Six Sigma Master Black Belt, Business Agility mentor, Scrum expert and project management lecturer. He leads Karv Training's in-person delivery in Ireland.
John Leech
Trainer, in-person delivery
John has worked in eCommerce and digital strategy for 25 years. He was eCommerce and Web Director at Lenovo International, built and managed a European eCommerce business, and now advises businesses on strategy and AI adoption with WSI Business Builders and Elemental AI. He delivers Karv Training's in-person workshops in Ireland alongside Padraig.
Questions credit unions ask.
Does the EU AI Act apply to credit unions in Ireland?
Yes. The AI Act applies to every provider and deployer of AI systems in the EU, with no exemption for credit unions and no size threshold. A credit union is a deployer when its staff or volunteers use an AI system at work, including ChatGPT, Microsoft Copilot or AI features inside its lending and member service software.
Do credit union volunteer directors need AI literacy training?
If they use AI on the credit union's behalf, yes. Article 4 covers staff and other persons dealing with the operation and use of AI systems on the organisation's behalf, and it does not turn on whether someone is paid. Directors are also subject to the Central Bank's fitness and probity regime, so we recommend that the board attends and is listed on the record.
What does Article 4 require after the Digital Omnibus?
Since 27 July 2026, Article 4 requires providers and deployers to take measures to support the development of AI literacy among their staff and others using AI on their behalf. It states that they are not required to guarantee any specific level of AI literacy of any individual. The European Commission says no certificate is required and that organisations can keep an internal record of training.
Is creditworthiness scoring high-risk under the AI Act?
Yes, where AI does it. Annex III point 5(b) lists AI used to evaluate the creditworthiness of natural persons or establish their credit score as high-risk, with an exception for fraud detection. The obligations on deployers of those systems apply from 2 December 2027, and a system already in service before then is brought in once its design changes significantly.
What does the Central Bank of Ireland expect from credit unions using AI?
The Central Bank's Regulatory and Supervisory Outlook 2026 says firms deploying AI should make sure the use fits the business problem, set clear accountability with human oversight and explainability, keep governance proportionate, and have processes to meet their AI Act obligations. We have not found Central Bank guidance written for credit unions on Article 4, and we will update this page if it publishes any.
Can a credit union be fined for not doing AI literacy training?
Not under Article 4 itself. Article 4 is not on the Article 99 fines list, and Ireland's Regulation of Artificial Intelligence Act 2026 attaches no notice or fine to it. It is still a legal duty, and the exposure sits in the law around it: fitness and probity, data protection, and the Article 50 transparency rules, which do carry fines.
We are merging with another credit union. Whose record applies?
The record belongs to the organisation that took the measure. After a transfer of engagements, the combined credit union has new staff, and often new systems, that the old record does not cover. A follow-up session adds them to the record as a dated entry.
Book a 20-minute call.
Twenty minutes to work out which tools your credit union runs, who uses them and which workshop fits. You get the price on the call. If you do not need us, we will say so.
Related insights.
Article 4
What changed in Article 4 of the EU AI Act in July 2026?
Regulation (EU) 2026/1744, the Digital Omnibus on AI, rewrote Article 4 on 24 July 2026. The duty is now to take measures that support AI literacy, no specific level is mandated, and what gets assessed is what your organisation did.
Records
What record should we keep to show we met Article 4?
Keep an internal record of the training and guidance you provided: what was covered, who attended, when, and why that depth suited those roles. The Commission says no certificate is required and that organisations can keep an internal record instead.
Enforcement
What happens if we ignore Article 4 of the EU AI Act?
Article 4 carries no fine of its own, under Article 99 or under Ireland's Regulation of Artificial Intelligence Act 2026. The exposure sits in the Irish law around it: directors' duties, data protection, Central Bank conduct standards and Article 50.
Sources
- Regulation (EU) 2024/1689, the AI Act, Articles 4, 26, 50, 99 and 111 and Annex III point 5
- Regulation (EU) 2026/1744, the Digital Omnibus on AI
- European Commission, AI literacy: questions and answers
- Regulation of Artificial Intelligence Act 2026 (No. 31 of 2026), Part 8
- European Union (Artificial Intelligence) (Designation) Regulations 2025 (S.I. No. 366 of 2025)
- Central Bank of Ireland, Regulatory & Supervisory Outlook 2026, Spotlight 1
- Central Bank of Ireland, Individual Accountability Framework
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.
Bank, lender or insurer? See AI literacy training for financial services.