the work

training

Three rules ask for training, and the AI Act adds its own. One small programme with one attendance record answers them all. The failure that shows up is having no record.

NIS2 / DORA / GDPR / AI Actlast checked 2 November 2026not legal advice
01

the reality

A weak slide is a smaller problem than no record. Keep the programme small, repeat it yearly and keep the sheet.

The AI literacy duty changed in July 2026 and now says it does not require guaranteeing a specific level for any individual. So a short session about your actual tools is a reasonable measure for a company of this size. The AI Act page has the rest.

basis NIS2 Art. 21(2)(g); AI Act Art. 4 as replaced by Regulation 2026/1744 Art. 1

02

what to decide

  • Which AI tools are allowed, for what, and who to askboard, on a proposal from IT
  • Who owns the programmeHR, with the head of IT
  • When management trainschair

basis AI Act Art. 4 as replaced by Regulation 2026/1744 Art. 1; NIS2 Art. 20(2)

three audiences, one programme

everyoneadmins and ITmanagement
spot and report something oddgets itgets itgets it
what may go into an AI toolgets itgets itgets it
lessons from your own incidentsgets itgets it
duties: approve, oversee, askgets it

basis NIS2 Art. 20(2), 21(2)(g); DORA Art. 13(6); AI Act Art. 4; KSC Art. 8e. The split by topic is practice.

03

what to build

  1. For everyone, 30 minutes a year (your choice): spotting phishing, reporting something odd, what data may go into an AI tool, who to call.
  2. For management, one session on their duties: approving, overseeing, what to ask.
  3. For admins, one session on what your own incidents and risk assessment turned up.
  4. Add your AI rules to the session. That is the core of your AI literacy measures.
  5. Keep the attendance list and the slides together, and chase people who missed it.

basis NIS2 Art. 21(2)(g); DORA Art. 13(6); GDPR Art. 39(1)(b); IR 2024/2690 Annex 8.1, 8.2 as a reference. Length and topics are practice.

04

the evidence it leaves

what you can showwho owns itrefresh
attendance record: name, date, sessionHReach session
the material as delivered, with versionhead of ITyearly
management training recordcompany secretaryyearly
written AI use rulesboardyearly

basis KSC Art. 8e(3). The rest is practice.

one session, one sheet

  1. 1run the sessionshort, about your own tools and incidents
  2. 2take attendancename, date, session
  3. 3keep the materialwith its version

that sheet helps answer

  • NIS2training, and management's own
  • DORAcompulsory modules
  • GDPRawareness of staff
  • AI Actliteracy measures

basis NIS2 Art. 20(2), 21(2)(g); DORA Art. 13(6); GDPR Art. 39(1)(b); AI Act Art. 4

05

what goes wrong

training with no record

If there is no sheet, there is nothing to show. Keep it from the first session.

the board skips it

NIS2 names management specifically, and Poland makes it yearly and documented.

AI rules nobody wrote

Staff are already using these tools. Silence is a decision too.

basis NIS2 Art. 20(2); KSC Art. 8e(1), 8e(3)

06

what the texts leave open

  • What counts as enough. No text sets hours or a syllabus, though DORA requires the modules to be compulsory, for all staff and senior management.
  • Whether phishing test results belong in your evidence. They are useful for you, and they do not replace a record that training happened.

basis DORA Art. 13(6)

07

check it yourself

fyi Last checked 2 November 2026. This is not legal advice. It is a plain reading of the texts listed on this page, and national law can add to them. Before you rely on it in front of a regulator, an auditor or your board, have a lawyer confirm it for your company. What this means.

your next step

Put a 30-minute session in the calendar for next month and create the attendance sheet today.