In a note published on 2 September 2026 on the CEN-CENELEC website, CEN announced the publication of CWA 18398 “AI Professional Role Profiles and Educational Profiles”, presented as a common reference for describing roles, skills and educational profiles in Artificial Intelligence and for linking them to established education types and proficiency levels (CEN-CENELEC). The document, approved by the workshop on 22 May 2026, is dated June 2026 and is available on the CEN-CENELEC website (CEN-CENELEC). On 8 September UNI, the Italian national standardisation body, reported the news, describing the document as a set of “guidelines for describing roles, competences and educational profiles relating to AI” (our translation) (UNI). In Italy UNI 11621-8:2026 has been in force since 30 April 2026; we have described its twelve professional AI profiles between national standard and European CWA (UNI), and Information Circular DC No 21/2026 of 17 June 2026 issued by Accredia, the Italian national accreditation body, adopted it as the reference for an accredited certification scheme (Accredia). The relationship between the two documents depends first of all on their legal nature, and that is where it is worth starting.
CWA 18398: roles, educational profiles and learning outcomes
According to CEN, the CWA does not offer an exhaustive taxonomy but an initial reference point for the codification of the profession; it presents role profiles and educational profiles, maps competences, levels and skills, distinguishes between lay users, professionals and AI professionals, and places itself in relation to other standardisation deliverables and to Regulation (EU) 2024/1689, the AI Act. CEN adds that the document will support trainers and educators who intend to match learning outcomes to the different AI roles at different levels (CEN-CENELEC). The announcement of the workshop, in April 2025, indicated its foundations: the European e-Competence Framework (EN 16234-1), the ICT role profiles of CWA 16458 and the guidelines for developing ICT professional curricula of TS 17699 (CEN-CENELEC). UNI, for its part, names among the addressees those responsible for training, “who will be able to offer a learning pathway based on the CWA guidelines outlined for each professional AI profile” (UNI).
The text describes thirty-seven role profiles, grouped into seven families (data processing and analysis, development, operations, support, guidance, management, governance), linked to the e-CF competences, and warns that the relationship between those profiles and the categories of operators under the AI Act is not one-to-one, because the Regulation assigns obligations to organisations and not to roles (CEN-CENELEC). The CWA describes professional roles, not addressees of obligations. The content of UNI 11621-8, a standard available for a fee, cannot by contrast be consulted: a point-by-point comparison between the two documents remains to be carried out on the texts, and here we confine ourselves to the training purpose of the CWA and the certification role of the UNI standard.
The legal nature of the CWA: a workshop agreement under CEN-CENELEC Guide 29
CEN and CENELEC define the CWA as an agreement developed and approved in a workshop open to anyone with an interest, with no geographical limits; the CWA does not have the status of a European standard, involves no obligation at national level and must be withdrawn if a subsequent European standard conflicts with it (CEN-CENELEC). CEN-CENELEC Guide 29 specifies that the CWA reflects an agreement between identified individuals and organisations responsible for its content, and that stakeholder involvement is limited to those directly interested in the subject; national members are not obliged to adopt it or to withdraw conflicting national standards, and they notify whether and how they will make it available in their country. The CWA is not designed to support European legislative requirements, carries a statement on limitation of liability, is valid for three years, unless confirmed, and, six years after its first publication, is submitted to the Technical Boards for a decision on its withdrawal (CEN-CENELEC).
The CWA expresses the agreement of the workshop participants, not the consensus of the standardisation system as a whole. We drew the consequences in our analysis of UNI 11621-8: the CWA requires no withdrawal or adjustment of the Italian standard and coexists with it.
Accredited certification: the UNI standard within the framework of Law No 4/2013
UNI presents UNI 11621-8 as the part devoted to non-regulated professional activities in the ICT field, built in continuity with the methodology of Part 1 and with the e-CF, with the aim of “making competences transparent, comparable and certifiable” (UNI). The legislative framework is Law No 4 of 14 January 2013 on unorganised professions. Article 6(2) bases the qualification of the professional service on conformity with “UNI ISO, UNI EN ISO, UNI EN and UNI technical standards” (our translation); Article 9(2) provides that accredited certification bodies “may issue, at the request of the individual professional, even one not registered with any association, the certificate of conformity with the UNI technical standard defined for the individual profession” (Official Gazette (Gazzetta Ufficiale)).
The CWA, as such, does not appear among the types listed in Article 6 and is not the UNI standard defined for a profession. In the mechanism of Law No 4 of 2013 the reference for certification is the UNI standard, not the CWA. The Accredia Circular set the rules for accrediting the bodies that certify persons under ISO/IEC 17024, whose scheme, examination and impartiality safeguards we have described, in the scheme referring to UNI 11621-8 and UNI 11506; the certificate must state both standards and the full name of the profile (Accredia).
Training and certification: the link in learning outcomes
The point of contact between the two documents lies in learning outcomes. According to CEN, the CWA serves to match learning outcomes to roles; the Accredia Circular requires the assessment to include “a combination of methods suitable for ensuring effective verification of learning outcomes” and the review of the application to include analysis of the curriculum vitae, “supplemented by documentary evidence proving the work and training activities declared by the candidate” (our translation). In our view this is where a pathway built on the CWA finds its place: it enters certification as evidence of training, not as the outcome of the assessment.
Two profiles in our articles show why this link is needed. In the portrait of the AI Prompt Engineer, an often misunderstood craft we reported the European needs analysis of the ARISA project, which points to an almost non-existent training offer against urgent demand. In the profile of the AI Deep Learning Engineer, between theoretical foundations and market demand we observed that, in a market where short courses promise specialists in a few weeks, third-party verification gives the qualification a measurable content. Both are among the profiles for which the Circular considers practical tests appropriate, in addition to written and oral tests; neither appears, under that name, among the titles of the thirty-seven profiles of the CWA (CEN-CENELEC). We consider that the CWA can help to structure the missing training offer, while the measurement of competences remains entrusted to the tests of the accredited scheme.
The new Article 4 of the AI Act and the “European competence frameworks”
Regulation (EU) 2026/1744, the Digital Omnibus, in force since 27 July 2026, replaced Article 4 of the AI Act: providers and deployers “shall take measures to support the development of AI literacy” of their staff and of anyone dealing with the operation and use of the systems on their behalf, and the obligation “does not require providers or deployers to guarantee any specific level of AI literacy of any individual”. Paragraph 3 provides that the AI Board shall adopt recommendations “taking into account European competence frameworks” (EUR-Lex). According to the Commission, work on those recommendations is under way, and supervision of Article 4 falls to the market surveillance authorities from 2 August 2026 (European Commission).
Article 4 does not define the “European competence frameworks”; recital 8 of the Digital Omnibus mentions, by way of example, the Digital Competence Framework for Citizens (DigComp) and the AI Literacy Framework for Primary and Secondary Education (EUR-Lex), both addressed to people in general and not to AI professionals. Whether CWA 18398 will be considered among them is for the recommendations to say. The CWA, approved before the Digital Omnibus entered into force, still reads Article 4 in its original wording based on a sufficient level and entrusts to a dedicated profile, the AI Educator, literacy programmes supporting compliance (CEN-CENELEC): this is precisely the benchmark that the rewording removed, as Nicola Fabiano observes (NicFab). Moreover, according to UNI’s presentation, UNI 11621-8 excludes from its scope the mere user of existing tools, whereas literacy concerns staff as a whole. Professional profiles, whether European or national, are not the benchmark of the literacy obligation in Article 4.
Critical aspects: missing correspondences, the duration of the CWA and the value of training certificates
The first aspect concerns correspondences. Neither the public sources consulted nor the CWA, whose table of contents includes no annex mapping it to UNI 11621-8, offer a correspondence table between the profiles of the two documents; deducing it from the similarity of names would expose training pathways to the risk of not preparing for the expected assessment.
The second concerns duration. A CWA that is valid for three years and submitted after six years to a decision on its withdrawal requires anyone anchoring a curriculum to it to plan for its revision from the outset.
The third concerns training certificates. Since the CWA, by its nature, is not intended to support legislative requirements, a training certificate built on the CWA is not equivalent to accredited certification of competences. It is the same caution we suggested with regard to ISO/IEC 17024, when we advised wariness of certificates lacking an examination or accreditation.
Conclusions
CWA 18398 and UNI 11621-8 share the e-CF root, but operate on distinct planes. Training providers and universities would do well to use the CWA to define levels and learning outcomes, stating in a verifiable manner which profile of the Italian standard their pathways prepare for. Accredited certification bodies remain responsible for assessment under the scheme based on UNI 11621-8 and UNI 11506, within the framework of Law No 4 of 2013. Providers and deployers retain the obligation in Article 4 of the AI Act, which neither document measures. Pending a public correspondence table and the recommendations of the AI Board, the comparison between the two documents must be made on the texts and on learning outcomes, not on the names of the profiles.
Author: Valentina Grazia Sapuppo
