AI Governance & Regulation: EU AI Act, NIST AI RMF and ISO/IEC 42001Operating AI governance in a company · Lesson 13 of 17

AI inventories and impact assessments

Article · 16 min · 8 min lecture

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AI inventories and impact assessments

13 chapters · about 8 min · full transcript

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Chapter 1 of 13

Inventory and impact

  • You can't govern what you can't see
  • Find shadow AI
  • Rate risk consistently
  • Pick the right assessment

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Chapters

The inventory is the foundation

Every governance framework starts with knowing what you have. The EU AI Act's obligations depend on classification; ISO/IEC 42001 requires you to identify AI systems in scope; NIST's Map function needs a use-case description. Without an inventory, none of these work.

What to record for each AI system or use case

FieldWhy
ID, name, descriptionUnambiguous reference
Business owner and technical ownerAccountability
Vendor, product, model and versionDue diligence and change tracking
Purpose and intended use (and prohibited uses)Classification depends on purpose
Users and affected peopleImpact and transparency duties
Data inputs (personal? special category? client confidential?)Privacy and security
Outputs and decisions (advice, content, decision about a person?)Risk level
Degree of autonomy and human oversightOversight design
Jurisdictions of users and affected peopleWhich laws apply
EU AI Act role and tier; Article 50 dutiesLegal obligations
Risk rating (likelihood x impact) and key risksPrioritization
Controls in placeEvidence
Status (proposed, pilot, production, retired) and review dateLifecycle

Finding shadow AI

  • Survey staff with a short, non-punitive form: "Which AI tools or features do you use for work?"
  • Check expense reports and card statements for AI subscriptions.
  • Review SSO and OAuth app grants, browser extension lists and network logs where available.
  • Ask vendors of existing software which AI features are on by default.

Risk rating that is quick and consistent

Use a simple scale and write down the reasoning.

ImpactDescription
1 LowInternal, easily corrected, no personal data
2 ModerateClient-facing content or limited personal data; errors are visible but recoverable
3 HighDecisions or advice affecting individuals, significant personal data, public-facing at scale
4 SevereLegal effects on people, special category data, safety, or high-risk AI Act uses

Likelihood 1 to 4 based on autonomy, volume and maturity of controls. Risk = impact x likelihood. Any score of 9 or more, or any impact of 4, needs an impact assessment and AI lead approval.

Impact assessments: which one when?

AssessmentTriggerFocus
AI system impact assessment (ISO/IEC 42001, guided by 42005)Your own threshold, for example risk score 9+Impacts on individuals, groups and society across the lifecycle
Data protection impact assessment (GDPR Art. 35, UK GDPR, similar laws)Processing likely to result in high risk to individuals, including innovative technology and systematic evaluationPrivacy risks and mitigations
Fundamental rights impact assessment (AI Act Art. 27)Certain deployers of high-risk systems (public bodies, public services, credit scoring, life/health insurance)Fundamental rights risks, affected groups, oversight, complaints
Algorithmic/bias auditCertain local laws (e.g. NYC LL 144 for hiring tools) or your policyDisparate impact across groups

Combine where possible: one template with a core section and add-on modules avoids duplicate work.

A combined impact assessment template (outline)

  1. Description: purpose, context, users, affected people, data, outputs, autonomy.
  2. Necessity and proportionality: why AI, alternatives considered, data minimization.
  3. Stakeholders: who could be affected, including vulnerable groups; how you consulted them.
  4. Risks: accuracy and confabulation, bias and discrimination, privacy, security (including prompt injection), transparency, over-reliance, IP, reputational and environmental.
  5. Mitigations and controls: technical, procedural, human oversight, disclosure.
  6. Residual risk and decision: approve, approve with conditions, reject; who decided.
  7. Monitoring and review: metrics, triggers for reassessment (model change, new market, incident).
  8. Add-on modules: GDPR DPIA items; AI Act FRIA items where applicable.

Worked example: a Jeddah real-estate agency's lead-scoring model

The agency plans AI that scores inbound leads for sales priority using form data and website behavior.

  • Impact 2 (it affects which prospects get a fast callback, not access to housing or credit), likelihood 3 (fully automated routing). Score 6: no mandatory assessment under their policy, but because it profiles individuals using personal data, KSA PDPL duties apply and they run a light DPIA anyway.
  • Risk found: the model might deprioritize leads from certain neighborhoods, a proxy for socioeconomic status. Mitigation: remove postcode as a feature; monthly check of callback rates by region; all leads get a response within 24 hours regardless of score.

Hands-on: inventory as code

- id: AI-007
  name: "Lead scoring"
  owners: {business: "Head of Sales", technical: "CRM admin"}
  vendor: {product: "CRM predictive scoring add-on", model: "vendor-proprietary", version: "2026.08"}
  purpose: "Prioritize inbound leads for callback order"
  prohibited_uses: ["pricing", "deciding eligibility for viewings or rentals"]
  data_inputs: ["form fields", "site behavior"]
  personal_data: true
  special_category: false
  jurisdictions: ["KSA", "UAE"]
  eu_ai_act: {in_scope: false, reason: "No EU users or outputs"}
  autonomy: "automated routing; humans can override"
  risk: {impact: 2, likelihood: 3, score: 6}
  assessments: ["DPIA-light 2026-09"]
  controls: ["postcode removed", "24h response floor", "monthly regional fairness check"]
  status: production
  review_date: 2027-03-01

Keeping the inventory in YAML or a spreadsheet with fixed columns lets you filter, report and diff changes over time.

Pitfalls

  • Inventorying tools but not use cases. One chat assistant may power five use cases with different risks.
  • Doing a big assessment once and never revisiting when the model, data or market changes.
  • Assessments written after launch to justify a decision already made.

Key takeaways

  • An AI inventory records owners, vendor/model/version, purpose, data, outputs, autonomy, jurisdictions, AI Act tier, risk and controls per use case.
  • Find shadow AI through non-punitive surveys, expenses, SSO grants, extensions and vendor feature checks.
  • A simple impact x likelihood score with a threshold decides when a deeper assessment and approval are required.
  • Combine AI impact assessment, DPIA, FRIA and bias audit needs in one template with add-on modules, and reassess on change.

Check your understanding

Quick questions to lock in the lesson. They don’t count towards your certificate.

  1. Why should the inventory record use cases rather than only tools?
  2. Which assessment is triggered under the EU AI Act for a bank deploying a high-risk credit-scoring system?
  3. When should an AI impact assessment be done?

Put it into practice

Convert your tool list into YAML inventory entries, one per use case. Rate impact and likelihood, and mark any entry that crosses your assessment threshold.

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