AI Inventory

/ai-inventory

When this runs

The user wants to manage their AI system inventory under the EU AI Act. The

core idea the skill exists to enforce: **role and tier are per-system, not

per-company.** A single organization can be a *provider* of System A, a

*deployer* of System B, and an *importer* of System C. Each combination

triggers a different set of obligations under the AI Act. The inventory

exists so those assessments are tracked where you can find them — the

obligations themselves are derived in conversation, not from a table.

What to do

• Read the config. Read

~/.claude/plugins/config/claude-for-legal/ai-governance-legal/CLAUDE.md.

If it doesn't exist or still has [PLACEHOLDER] markers, direct the user

to /ai-governance-legal:cold-start-interview first.

• Read the inventory. Inventory lives at

~/.claude/plugins/config/claude-for-legal/ai-governance-legal/ai-systems.yaml.

If it doesn't exist, create it with an empty systems: list when the

first add runs.

• Dispatch on the argument:

• No argument, or list → show the inventory table (see List below).
• add → run the Add flow.
• edit <id> → show the current record, ask what to change, update one

field, confirm, write.

• classify <id> → run the Classification walk-through on an

existing record, updating role, tier, role_basis, and tier_basis.

• show <id> → show the full record.

• On list, offer the dashboard:

"Want the full dashboard? Filter by status / tier / EU nexus / owner.

Say the word."

• Close every action with a hook into the lawyer's work.

After any write, say:

> Recorded. When you're ready to walk through obligations for this

> system, just ask — I'll do it in-conversation and flag where the AI

> Act article mapping needs your verification. I don't derive

> obligations from a table because the mapping is complex and changing.

List format

Render as a compact table:

| ID | Name | Owner | Status | EU nexus | Role | Tier | Next review |

|----|------|-------|--------|----------|------|------|-------------|

| sys-001 | Resume screening | HR / Jamie | in_production | yes | deployer | high_risk | 2026-08-01 |

| sys-002 | Email drafting assistant | IT / Priya | in_production | no | deployer | limited | 2026-12-01 |

Under the table, show counts by tier and a line: "N systems flagged for

review within 30 days."

Add flow (interview)

Ask, one field at a time (or accept a paste). The required fields are

name, owner, description, status, eu_nexus. The rest can be

deferred — say so explicitly: "you can come back to classification with

/ai-governance-legal:ai-inventory classify <id>."

• Name. Short label for the system.
• Owner. Person or team accountable for it day-to-day.
• Description. One or two sentences. What does it do, and against

what data?

• Status. planned | in_development | in_production | deprecated.
• EU nexus. Is the system deployed in the EU/EEA, offered to users in

the EU/EEA, or used to produce outputs that affect people in the

EU/EEA? If any of these are true, EU AI Act analysis applies.

• Proceed to classification? Offer to run the walk-through now, or

skip and come back later.

Assign an ID: sys-NNN where NNN is the next integer in the file.

Classification walk-through

The walk-through produces role, role_basis, tier, tier_basis. Both

bases are tagged [verify against current AI Act text] — not because the

skill is hedging, but because the article mapping is complex and the AI

Act is still phasing in. The lawyer owns verification.

Step 1: Role

> Who does what to this system?

Options, with the distinguishing test:

• Provider — you develop it (or have it developed) and place it on the

EU market or put it into service under your own name or trademark.

• Deployer — you use it under your own authority, not for personal

non-professional use. (Most common inside companies.)

• Importer — you bring an AI system into the EU from a provider

established outside the EU.

• Distributor — you make an AI system available on the EU market

without being the provider or importer.

• Authorized representative — you act on behalf of a non-EU provider

and are established in the EU.

• Product manufacturer — you put a general-purpose AI system (or

another AI system) into a product under your own name/trademark. Treated

as provider for the product.

Dual-role flag. If the user substantially modifies a vendor system

(fine-tunes on their own data, changes the intended purpose, rebrands),

they may become a provider of the modified system even if they started

as a deployer. Call this out when they describe any modification beyond

configuration. `[verify against current AI Act text — Article 25, provider

obligations and substantial modification]`

Write the role. Write role_basis in one sentence.

Step 2: Tier

> **What does the system do, and does the use case fall into a regulated

> category?**

Check in order:

A. Article 5 prohibited practices. `[verify against current AI Act

text — Article 5]`

Summaries, not definitive text:

• Subliminal or deceptive techniques materially distorting behavior
• Exploiting vulnerabilities (age, disability, socio-economic status) to

materially distort behavior

• Social scoring by public authorities leading to detrimental treatment
• Real-time remote biometric ID in publicly accessible spaces for law

enforcement (narrow exceptions)

• Biometric categorization inferring race, political opinions, union

membership, religious or philosophical beliefs, sex life, or sexual

orientation

• Emotion recognition in the workplace or education (medical and safety

exceptions)

• Facial image database scraping from the internet or CCTV
• Predictive policing based solely on personality traits

If matched → tier is prohibited. Flag the use case as stop and route to

the governance team's prohibited-practice workflow.

B. Annex III high-risk areas. `[verify against current AI Act text —

Annex III]`

Summaries:

• Biometric identification and categorization
• Critical infrastructure (digital infrastructure, road traffic, supply of

water / gas / heating / electricity)

• Education and vocational training (access, evaluation, proctoring,

monitoring prohibited behavior)

• Employment, worker management, self-employment access — recruitment,

selection, promotion, termination, task allocation, monitoring, performance

• Essential private and public services (public benefits, credit scoring

for individuals, risk assessment and pricing for life/health insurance,

emergency dispatch)

• Law enforcement (risk assessment, polygraphs, deepfake detection,

reliability of evidence, profiling)

• Migration, asylum, border control (risk assessment, travel document

verification, examination of applications)

• Administration of justice and democratic processes (research and

interpretation, influencing elections)

If matched → tier is high_risk. Note the Annex III area and subsection.

C. GPAI. `[verify against current AI Act text — Article 51 and

surrounding]`

• GPAI: model trained on broad data at scale, designed for generality,

capable of competently performing a wide range of distinct tasks.

• GPAI + systemic risk: cumulative compute > 10^25 FLOPs, or designated

by the Commission.

D. Limited risk. Chatbots interacting with natural persons, deepfakes,

emotion recognition and biometric categorization systems outside Article 5

scope — transparency obligations apply.

E. Minimal risk. Everything else.

Write the tier. Write tier_basis in one sentence, citing the article or

Annex entry that matched, tagged [verify against current AI Act text].

Step 3: Recommendations

Offer three next steps:

• "Want me to walk through obligations for this system? I'll do it in

conversation — I don't derive them from a table."

• "Want to run /ai-governance-legal:aia-generation to produce a full

impact assessment?"

• "Want to set a next review date? I'll add it to the inventory."

Record format

systems:
  - id: sys-001
    name: "Resume screening tool"
    owner: "HR / Jamie"
    description: "Filters inbound CVs against job criteria"
    status: in_production          # planned | in_development | in_production | deprecated
    eu_nexus: true                 # deployed, offered, or affects people in the EU/EEA
    role: deployer                 # provider | deployer | importer | distributor | authorized_rep | product_manufacturer
    role_basis: "We license from VendorX and deploy internally [verify against current AI Act text]"
    tier: high_risk                # prohibited | high_risk | limited | minimal | gpai | gpai_systemic
    tier_basis: "Annex III(4)(a) — employment, recruitment selection [verify against current AI Act text]"
    obligations_assessed: false
    obligations_note: "To assess: as deployer of a high-risk system — human oversight, input data quality, monitoring, record-keeping, informing workers, FRIA if public body/service — see Article 26 [verify against current AI Act text]"
    next_review: "2026-08-01"
    review_trigger: "on substantial modification or annually"
    created: "2026-05-11"
    updated: "2026-05-11"

Why this skill does NOT auto-derive obligations

The inventory stores role, tier, and the basis for each. It does NOT

contain a hardcoded role × tier → obligations table.

When the user asks "what are my obligations for System X?", the skill

does the analysis in conversation, tagged [verify], and routes to

/ai-governance-legal:aia-generation for the formal impact assessment

if needed.

This is deliberate:

• Article mapping is complex and the AI Act is phasing in through 2027.
• Confident-and-wrong on a compliance obligation ends up in a board memo.
• The inventory is a registry for the lawyer. The lawyer owns the

obligation analysis.

Guardrails

• Never classify silently. The classification walk-through must be

visible; do not auto-classify from a system description.

• [verify] tags stay. They are not hedging — they are the point.

Do not strip them in outputs.

• Flag substantial modification. Whenever a system is modified beyond

configuration, prompt the user to re-run /ai-inventory classify —

modification can change role.

• Don't declare obligations from a table. If asked, do the analysis

in conversation and route to /aia-generation for anything that needs

a formal record.