AI System Inventory & Classification Workbook — EU AI Act

Step one of every AI Act programme: list your systems, then classify them along a decision path that puts the carve-outs before Annex III. The tier is derived from your answers, not typed.

You cannot classify what you have not listed, and you cannot budget a programme without knowing how many systems land in each tier. This file does both, in the order that avoids the usual mistakes.

The order matters

Most classification exercises go straight to Annex III and ask "is this in the list?". That is how a fraud-detection model ends up classified as high-risk — it looks like credit scoring, and the carve-out that excludes it sits inside the same point.

The decision path here asks the eight questions in the order that gets the answer right:

1. Is it an AI system at all? Art. 3(1) requires inference. A deterministic rules engine is out entirely — and counting those is budget you do not spend.
2. Is it prohibited? Art. 5, in force since February 2025. Stop before anything else.
3. Does a carve-out apply? Financial fraud detection, 1:1 biometric verification, creditworthiness of legal persons.
4. Annex I? Then 2 August 2028.
5. Annex III? Then 2 December 2027.
6. Does the Art. 6(3) filter apply — and is it void because the system profiles natural persons?
7. Does Art. 50 transparency apply regardless?
8. Are you provider or deployer, and does Art. 25 flip it?

The tier is derived, not typed

You answer five yes/no questions per system. The workbook computes the tier. That matters more than it sounds: a classification someone typed is an opinion, while a classification a formula derived from stated answers is an audit trail. If a supervisor disagrees, you can show which answer drove the outcome.

Empty rows stay empty — they do not silently count as high-risk. The summary tab gives you the counts a budget conversation needs: systems listed, out of scope, prohibited, high-risk, not high-risk.

What usually happens

Organisations come out of this with far fewer high-risk systems than they feared, and one or two they had not noticed — typically in HR, because Annex III point 4 catches you as an employer whatever your sector.

If every system in your inventory comes out high-risk, the classification is wrong. The file says so explicitly, and tells you which three carve-outs to re-read.

What it covers in the regulation

• Art. 3(1) — is it an AI system
• Art. 5 — prohibited practices
• Annex I / Annex III
• Art. 6(3) — the filter
• Art. 25 — provider or deployer