Template · Written by Yobel Tzegai · Last checked 9 October 2026

What goes in an AI inventory for the EU AI Act?

One row per AI system: what it is for, whether you are its provider or deployer, its risk class and the provision it rests on, its owners and the person who confirmed the classification on a stated date. The Regulation never uses the word inventory, so this free template from complipath.io says for each column which provision it helps you answer.

Check your AI systems, free

Download it, with no email asked

What is in it

AI inventory template (CSV and XLSX): the columns, what goes in each and the provision it serves
ColumnWhat goes in itProvision
AI systemThe name your teams use for it, one row per system and intended purpose.Practice, not law
Intended purposeWhat it is used for and in which context. Article 3, point (12) defines it by the information the provider supplies in the instructions for use, promotional or sales materials and statements, as well as in the technical documentation.Article 3, point (12)
Your roleProvider if you develop it or have it developed and place it on the market or put it into service under your own name or trademark, whether for payment or free of charge. Deployer if you use it under your authority, other than in a personal non-professional activity.Article 3, points (3) and (4)
VendorThe company you bought it from, or the provider of the model you build on.Practice, not law
Business ownerThe person accountable for how it is used.Practice, not law
Technical ownerThe person who runs it technically.Practice, not law
Decides about peopleWhether you use it to make decisions, or to assist in making them, related to natural persons. For a high-risk Annex III system you deploy, Article 26(11) then has you inform those persons; for law enforcement purposes, Article 13 of Directive (EU) 2016/680 applies.Article 26(11)
Risk classProhibited (Article 5), high-risk (Article 6), transparency obligations (Article 50) or none of these. Article 50 obligations can apply alongside the high-risk ones: Article 50(6) says its paragraphs 1 to 4 do not affect the requirements and obligations of Chapter III.Article 5, Article 6 and Article 50
Provision it rests onThe exact provision behind the class, such as point 4(a) of Annex III with Article 6(2), or Article 6(1) with the Annex I legislation the product falls under.Article 6(1) and (2), Annex I and Annex III
Article 6(3) assessmentWhere you, as provider, consider an Annex III system not high-risk: the documented assessment Article 6(4) requires before it is placed on the market or put into service, and its registration under Article 49(2). An Annex III system that performs profiling of natural persons is always high-risk (Article 6(3), third subparagraph).Article 6(3) and (4)
Applies fromThe date the system's duties apply from, with the provision that sets it: for the high-risk duties of an Annex III system, 2 December 2027 (Article 113, third paragraph, point (c)(i), as replaced by Regulation (EU) 2026/1744).Article 113
Confirmed byThe person who confirmed the classification.Practice, not law
Confirmed onThe date they confirmed it.Practice, not law
Law versionThe text the classification answered, such as Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744, so you can tell which rows an amendment touches.Practice, not law
People who work with itWho operates or uses it on your behalf, so that your AI literacy measures reach them.Article 4(1), as replaced by Regulation (EU) 2026/1744
Next reviewWhen the row is checked again. A change of purpose, vendor or law is a reason to check it sooner.Practice, not law
Example rows for a fictional company, Harbrook. Not real data.
AI systemIntended purposeYour roleVendorBusiness ownerTechnical ownerDecides about peopleRisk classProvision it rests onArticle 6(3) assessmentApplies fromConfirmed byConfirmed onLaw versionPeople who work with itNext review
Support assistant (example)Answers Harbrook's customers in the help chatProvider[Model provider][Name], customer service[Name], engineeringNoTransparency obligationsArticle 50(1)Not applicable: not an Annex III system2 August 2026 (Article 113, second paragraph); the later date in Article 111(4) covers only Article 50(2)[Name][Date]Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744The customer service team[Date]
CV screening (example)Filters job applications for Harbrook's recruitersDeployer[Vendor][Name], people team[Name], ITYesHigh-riskPoint 4(a) of Annex III, with Article 6(2)Not applicable: Harbrook is the deployer2 December 2027 (Article 113, third paragraph, point (c)(i), as replaced)[Name][Date]Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744The recruiters who use it[Date]

The same work, in the app

Complipath's AI inventory keeps every AI system you build or use with its owners, its risk level, the provision it rests on and who confirmed it, and exports the whole register as a spreadsheet, as JSON or as a PDF with the law texts it was assessed against. register.

The provisions it names

Article 3, points (3), (4) and (12); Article 4(1), as replaced by Regulation (EU) 2026/1744; Article 5; Article 6(1) to (4); Article 16; Article 26; Article 49(2); Article 50; Article 113, second paragraph; Article 113, third paragraph, point (c), as replaced by Regulation (EU) 2026/1744; Annex I; point 4(a) of Annex III. Each is in Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744.

Starter

€499 a month

Prices exclude VAT.

  • Up to 20 AI systems
  • Every duty, deadline and article
  • Evidence and the audit log
  • Your first system is free, with no end date
Check your AI systems, free

All plans

Questions

Does the EU AI Act require an AI inventory?

Not by that name: the word does not appear in the Regulation. Its duties attach to each system, though, from the AI literacy measures of Article 4 for every provider and deployer to the high-risk duties of Article 16 and Article 26, and none of them can be met for a system nobody has listed.

Should systems that are not high-risk be in it?

Yes. Article 4 applies to providers and deployers of AI systems whatever the risk class, and Article 50 can apply to systems that are not high-risk. A row that records none of these, with the provision it was checked against and the person who confirmed it, is an answer you can show. A missing row is not.

Why record which version of the law a row answered?

Because the law changes. Regulation (EU) 2026/1744 replaced Article 113, third paragraph, point (c): Chapter III, Sections 1, 2 and 3, except Article 6(5), now apply from 2 December 2027 for systems high-risk under Article 6(2) and Annex III and from 2 August 2028 under Article 6(1) and Annex I.

How does Complipath keep the same record?

Complipath's AI inventory keeps each system with its owners, its risk level, the provision it rests on and who confirmed it, and exports the register as a spreadsheet, as JSON or as a PDF with the law texts it was assessed against. A rule engine decides the risk level and names the article, and a person confirms it.

Read next
See what your customers will ask about your AI.No account needed. Every answer cites the article it rests on.