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AI System Inventory

Ready

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A worked example shows this template completed for a fictional mid-size company.

Purpose. The single list of every AI system you build, buy, or have embedded in something you already licence. It is the foundation of AI Act compliance: every other obligation applies per system, so a system you have not listed is one you cannot govern.

When to use it. Create it now, before anything else. Add systems at ideation, not at launch. Review the whole inventory quarterly.

How to use it. Run a discovery sweep first — ask each team what AI they use, then check your SaaS contracts for AI features you did not know were switched on. Expect the real number to be two to three times what people initially report.

Closes assessment gaps

This template addresses Q03, Q05, Q06, Q07, Q08, Q22, Q38 in the readiness assessment.


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The template

Inventory fields

Field Notes
System ID Stable reference
Name & purpose What it does, in business language
Business owner The named AI Accountable Owner
Technical owner Who operates it
Build / buy / embedded Determines which policy applies
Vendor & product For bought or embedded
Our role Provider / deployer / importer / distributor
Risk tier Prohibited / high-risk / limited / minimal
Tier rationale Why — the decision, not just the label
Annex reference If high-risk, which Annex III point
Model / technique E.g. GPT-class LLM, gradient boosting
Data sources Links to Data Asset Register
Personal data? Triggers DPIA
Affects individuals? Triggers oversight and transparency duties
Lifecycle stage Ideation / dev / live / retired
Human oversight How, and by whom
Documentation Link to Model Card / Model Risk Documentation
Risk assessment Link to AI Risk Assessment
Last / next review

The inventory

ID System Owner Source Role Tier Personal data Stage Next review
AI-001 Demand forecasting [name] Build Provider Minimal No Live [date]
AI-002 Support summarisation [name] Buy (SaaS) Deployer Limited Yes Live [date]
AI-003 Credit decision support [name] Build Provider High Yes Live [date]
AI-004 CV screening [name] Buy Deployer High Yes Live [date]
AI-005 Marketing copy assistant [name] Embedded Deployer Limited No Live [date]

Finding what you already have

Most organisations under-count on the first pass. Look in all of these:

Where to look What you tend to find
Ask each team directly Tools bought on expenses or team cards
SaaS contracts and release notes AI features switched on by the vendor
Expense claims Individual AI subscriptions
Network / SSO logs Tools nobody declared
Code repositories Model APIs called directly
Data warehouse jobs Scoring pipelines nobody calls "AI"

Embedded AI is the blind spot

Your HR system, CRM, and helpdesk have almost certainly shipped AI features in the last two years. Some are high-risk uses under Annex III — CV screening especially. Nobody procured them as AI, so nobody assessed them.

Classification decision record

For each system, record the classification decision itself:

System Tier Rationale Decided by Date Challenged?
AI-004 High Annex III(4) — employment; screens candidates [committee] [date] No

A classification without a rationale cannot be defended later, and cannot be reviewed sensibly when the system changes.

Maintenance

Trigger Action
New system proposed Register at ideation, before build
Purpose changes materially Re-classify; re-assess
Vendor changes the model Review; re-assess if behaviour changed
Quarterly, including a review of vendor release notesUnless: Monthly if you have a large SaaS estate or an active procurement pipeline. Full review; confirm owners still in post
Retirement Mark retired; retain records per schedule

Adaptation notes

  • Small organisations: A spreadsheet is fine. The fields that must not be dropped are owner, role, tier, and rationale — everything else can be added later.
  • Large / federated organisations: Federate collection to business units with a group-level standard for tiering, or you will get four incompatible interpretations of high-risk.
  • Heavy vendor use: Add contract reference and renewal date, and link to your vendor assessment under Third-Party AI Risk Policy.

Not legal advice

These templates are a head start, not a substitute for professional judgement. Adapt them to your jurisdiction, sector, and risk appetite, and have qualified counsel review anything material before you rely on it.