/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
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
list when the
first
runs.
-
Dispatch on the argument:
- No argument, or → show the inventory table (see List below).
- → run the Add flow.
- → show the current record, ask what to change, update one
field, confirm, write.
- → run the Classification walk-through on an
existing record, updating role, tier, role_basis, and tier_basis.
- → 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
,
,
,
,
. 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:
where NNN is the next integer in the file.
Classification walk-through
The walk-through produces
,
,
,
. 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
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
. 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
. 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
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
yaml
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
, 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.
- 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 —
modification can change role.
- Don't declare obligations from a table. If asked, do the analysis
in conversation and route to for anything that needs
a formal record.