Skip to content
Template · for founders and product leads

The EU AI Act AI inventory, one row per feature.

The table every vendor questionnaire, investor request list and classification starts from. The columns, why each one is there, and a worked example.

Last updated 9 October 2026 · Regulation (EU) 2024/1689 as amended by the June 2026 Omnibus · Self-assessment, not legal advice

Every EU AI Act conversation starts with the same question. An enterprise buyer's questionnaire asks which of your features use AI. An investor's request list asks what the product does with it. Your own classification cannot start until you know. The answer is an AI inventory: one table, one row per AI system, dated. This page gives you the columns, explains why each one is there, and walks through a fictional example so you can see what a finished one looks like.

The Act classifies AI systems (Article 3(1)), not companies. One product can hold a minimal-risk feature, a limited-risk chatbot and a high-risk scoring model at the same time. That is why the inventory has one row per feature, not one row per product.

Why the inventory comes first

For most companies the Act does not require a document called an inventory. It requires things you cannot do without one: a risk classification for each system, a written assessment under Article 6(4) if you rely on the Article 6(3) exemption, a disclosure under Article 50 for each system that talks to people, and AI literacy under Article 4 for the staff who build or use them. Each of those starts from a list of the systems.

It is also the document other people ask for. It answers the first three questions of a typical vendor questionnaire, it is the first row of the data room folder investors expect, and it is where an authority would start if it ever asked.

Two lists, not one

Keep both in the same file. A buyer cares about the first list, an authority could ask about both, and Article 4 applies to both.

The columns

ColumnWhat to writeWhy
SystemThe feature's name as your team and your customers know itOne row per system
Intended purposeOne sentence: what it does, for whom, and what happens with the outputArticle 3(12). The tier follows the purpose
AI system?Yes or no, with the reason: does it infer its outputs, or follow rules people wrote?Article 3(1)
Model and model providerWhich model, from whom, called by API or fine-tuned by youArticle 53 stays with the model provider unless you modify the model substantially
Your roleProvider or deployerArticles 3(3), 3(4) and 25
People affectedWho sees the output, and whether it decides or scores anything about a personDecides most Annex III questions
EU linkPlaced on the EU market, or output used in the EUArticle 2
Article 5 check"None", or a note on anything near the lineProhibited practices, applied since 2 February 2025
Annex III or Annex I"None", or the point numberArticle 6(1) and 6(2)
Article 6(3)Relied on or not; if relied on, the date of the written assessmentArticle 6(3) and 6(4). Never available if the system profiles people
Article 50Which paragraph applies, the wording, and where it appears or how output is markedArticle 50(1) to 50(4)
TierProhibited, high, limited or minimalThe summary of the columns before it
Next dateThe next deadline that applies to this rowPost-Omnibus dates
Owner and review dateA named person, and when the row was last checkedKeeps it current

That looks like a lot, but most rows fill themselves in a minute. A feature with no decisions about people, no Annex III area and no chat interface needs "none" in five columns and is done.

Is it an AI system? The quick test

Article 3(1) defines an AI system as a machine-based system that, with some level of autonomy, infers from its input how to generate outputs such as predictions, content, recommendations or decisions. The word that matters is infers. A model that learned its behaviour from data, including any LLM call, is on the AI side. A routing rule that sends tickets containing "invoice" to billing is a rule a person wrote, and it is not. The Commission's guidelines on the AI system definition work through the borderline cases.

Do not mark a feature "no" because the model is someone else's. A feature that sends text to a third-party model and shows the answer is an AI system, and if it carries your name you are its provider.

A worked example

A fictional helpdesk SaaS with five rows. The product and its features are invented for illustration.

SystemAI?RoleTier and reasonNext date
Customer-facing support chatbotYesProviderLimited. Talks to the public: Article 50(1) disclosure in the greetingApplies now
Reply drafts for support agentsYesProviderLimited. Generates text: check who marks output under Article 50(2)2 Dec 2026
Keyword ticket routingNon/aOut of scope. Fixed rules written by peopleNone
Agent quality score used in staff reviewsYesProviderHigh. Annex III point 4: evaluates performance of workers. Profiles people, so Article 6(3) is not available2 Dec 2027
Chat assistant used by our own staffYesDeployerMinimal for this use. Article 4 literacy recordApplies now

Two things the example shows. The high-risk row is one feature, not the whole product, and it is the row a buyer or investor will ask about first. And the product's biggest live duty, the chatbot disclosure, is a single sentence.

Not sure whether a row sits in Annex III? The free high-risk checker runs the Annex III and Article 6(3) questions for one system in your browser. For the Article 50 column, the Article 50 disclosure generator drafts the wording.

Keeping it alive

An inventory is a record of your own assessment. It is not a certificate, and it should never be described as one. For limited-risk and minimal-risk systems there is no AI Act certificate to get: conformity assessment under Article 43 applies to high-risk systems only.

Each row is one classification. The free scan gives a likely risk tier for one system in about two minutes: eight questions plus your email. A Reglynn gap report turns one row into a dated, referenced position with the role analysis, the Article 6(3) and GPAI checks and the deadlines that apply to your answers; the 3-system and 10-system packs cover more rows. See a sample report. It is a self-assessment, not legal advice.

Frequently asked questions

Is an AI inventory mandatory under the EU AI Act?

For most companies the Act does not require a document called an inventory. It requires a classification per AI system, a written assessment under Article 6(4) if you rely on Article 6(3), Article 50 disclosures and Article 4 AI literacy. An inventory is the practical way to show all of them, and it is what buyers and investors ask for.

Does a feature that calls the OpenAI or Anthropic API count as an AI system?

Yes. A feature that sends input to a model and uses the inferred output is an AI system under Article 3(1). If you ship it under your own name you are its provider under Article 3(3). The model provider keeps the Article 53 duties for the general-purpose model.

How often should an AI inventory be updated?

Whenever something changes a row: a new AI feature, a new intended purpose, a new customer segment or a change of model provider. Date every row, and send the same version to buyers, investors and your contract schedules.

Classify one row in two minutes

The free scan gives a likely risk tier for one AI system: eight questions plus your email. The gap report turns that row into a dated document with the Articles and post-Omnibus deadlines that apply to your answers.

Get your risk tier

No card, no account. Full gap report from €59. See a sample report. Prices exclude VAT, added at checkout where applicable. 14-day refund.

Self-assessment, not legal advice. This page and the Reglynn report are a structured self-assessment based on the EU AI Act (Regulation 2024/1689, as amended by the June 2026 Omnibus). They indicate where you likely stand and what to verify with a qualified advisor. Reglynn is not a notified body and issues no certification.

How this was made. Reglynn reports are generated by an AI system built on Anthropic's Claude and delivered automatically. Reglynn is a Limited Risk AI system under Article 50; we disclose AI involvement wherever it occurs, including in our chat assistant. Our own self-assessment.