ai-inventory

name	ai-inventory
description	Per-system AI inventory — track each AI system's EU AI Act role and risk tier (where EU nexus exists), UK regulatory flags (ICO DPIA trigger, CMA, FCA model risk, MHRA, Ofcom), and UK GDPR Art. 22 automated decision-making status. Role and tier are assessed per system, not per company. Use when the user says "ai inventory", "add an ai system", "what systems do we have", "classify this ai system", "eu ai act register", "ai system registry", or "uk gdpr automated decisions register".
argument-hint	[list | add | edit <id> | classify <id> | show <id>]

/ai-inventory

When this runs

The user wants to manage their AI system inventory. The core idea the skill exists to enforce: role, regulatory flags, and obligations are per-system, not per-company. A single organisation can be a deployer of System A (internal productivity), a provider of System B (AI product sold to EU customers), and a consumer of System C (third-party SaaS with embedded AI). Each combination triggers a different set of obligations under UK law and, where EU nexus exists, the EU 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

1. Read the config. Read ~/.claude/plugins/config/uk-legal-plugins/ai-governance-legal-uk/CLAUDE.md. If it doesn't exist or still has [PLACEHOLDER] markers, direct the user to /ai-governance-legal-uk:cold-start-interview first.

2. Read the inventory. Inventory lives at ~/.claude/plugins/config/uk-legal-plugins/ai-governance-legal-uk/ai-systems.yaml. If it doesn't exist, create it with an empty systems: list when the first add runs.

3. 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, uk_flags, and their bases.
   • show <id> → show the full record.

4. On list, offer the dashboard: "Want the full dashboard? Filter by status / tier / EU nexus / UK regulatory flags / owner. Say the word."

5. 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 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	EU AI Act Tier	UK regulatory flags	Art. 22?	Next review
sys-001	CV screening	HR / Jamie	in_production	no	N/A	ICO high-risk	yes	2026-08-01
sys-002	Email drafting	IT / Priya	in_production	yes	limited	none	no	2026-12-01

Under the table, show counts by tier and UK flag, 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-uk:ai-inventory classify <id>."

1. Name. Short label for the system.
2. Owner. Person or team accountable for it day-to-day.
3. Description. One or two sentences. What does it do, and against what data?
4. Status. planned | in_development | in_production | deprecated.
5. 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. Otherwise: UK domestic analysis only.
6. Personal data involved? Does the system process personal data about individuals? This determines whether UK GDPR analysis applies (always for UK-based organisations).
7. Automated individual decisions? Does the system make or significantly influence decisions with legal or similarly significant effects on individuals? → UK GDPR Art. 22 flag.
8. 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 UK regulatory flags, Art. 22 position, and (where EU nexus) EU AI Act role/tier. All classification bases are tagged [verify against current text].

Step 1: UK regulatory flags (all UK systems)

Run through these UK-specific checks regardless of EU nexus:

A. UK GDPR / ICO flags

Personal data? If yes:

• Art. 22 automated decision-making: Is this system making or significantly influencing a decision that is (1) solely automated, (2) has legal or similarly significant effects on individuals? → Flag art22_triggered: true/false/unclear.
• Art. 35 DPIA required? Is this large-scale systematic monitoring, processing of special category data using new technology, or automated significant decision-making? → Flag dpia_required: true/false/unclear.
• ICO high-risk processing: Does ICO's guidance flag this type of processing as high-risk? → Flag ico_high_risk: true/false/unclear. [model knowledge — verify against current ICO DPIA list and guidance]

B. Sector-specific flags (only if applicable to this organisation's footprint)

• FCA/PRA model risk (PS7/24 / SS1/23): Is this a consequential AI system in a regulated financial services firm? → Flag fca_model_risk: true/false/na.
• MHRA AIaMD: Does this system meet the definition of a medical device? → Flag mhra_aimd: true/false/na.
• Ofcom/Online Safety Act: Is this system used in an online service with significant UK user numbers? → Flag ofcom_osa: true/false/na.
• ATRS (public sector): Is this a public sector AI system subject to Algorithmic Transparency Recording Standard? → Flag atrs_required: true/false/na.
• CMA: Does this system involve algorithmic pricing, recommendation, or foundation model capabilities that CMA's AI work is monitoring? → Flag cma_watch: true/false/na.

Step 2: EU AI Act classification (only if EU nexus)

If eu_nexus: false, skip this step and mark eu_ai_act_tier: na.

Who does what to this system with respect to the EU market?

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.
• 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 into a product under your own name/trademark.

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. [verify against current AI Act text — Article 25]

Write the role. Write role_basis in one sentence.

EU AI Act tier:

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 behaviour
• Exploiting vulnerabilities (age, disability, socio-economic status) to materially distort behaviour
• Social scoring by public authorities leading to detrimental treatment
• Real-time remote biometric ID in publicly accessible spaces for law enforcement
• Biometric categorisation inferring race, political opinions, union membership, religious or philosophical beliefs, sex life, or sexual orientation
• Emotion recognition in the workplace or education
• 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.

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

Summaries:

1. Biometric identification and categorisation
2. Critical infrastructure (digital infrastructure, road traffic, supply of water / gas / heating / electricity)
3. Education and vocational training (access, evaluation, proctoring, monitoring)
4. Employment, worker management, self-employment access — recruitment, selection, promotion, termination, task allocation, monitoring, performance
5. Essential private and public services (public benefits, credit scoring for individuals, risk assessment and pricing for life/health insurance, emergency dispatch)
6. Law enforcement (risk assessment, polygraphs, deepfake detection, reliability of evidence, profiling)
7. Migration, asylum, border control
8. Administration of justice and democratic processes

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

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

D. Limited risk. Chatbots interacting with natural persons, deepfakes, emotion recognition and biometric categorisation 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, tagged [verify against current AI Act text].

Step 3: Recommendations

Offer three next steps:

1. "Want me to walk through obligations for this system? I'll do it in conversation — I don't derive them from a table."
2. "Want to run /ai-governance-legal-uk:aia-generation to produce a full impact assessment?"
3. "Want to set a next review date? I'll add it to the inventory."

Record format

systems:
  - id: sys-001
    name: "CV screening tool"
    owner: "HR / Jamie"
    description: "Filters inbound CVs against job criteria before human recruiter review"
    status: in_production          # planned | in_development | in_production | deprecated
    eu_nexus: false                # deployed, offered, or affects people in the EU/EEA
    personal_data: true            # processes personal data about individuals
    # UK regulatory flags
    art22_triggered: true          # UK GDPR Art. 22 automated significant decision
    art22_basis: "deployer | solely automated initial shortlisting | employment outcome [verify]"
    dpia_required: true            # UK GDPR Art. 35 DPIA likely required
    ico_high_risk: true            # ICO high-risk processing flag
    fca_model_risk: false          # FCA/PRA model risk — n/a (not financial services)
    mhra_aimd: false               # MHRA AI as Medical Device — n/a
    ofcom_osa: false               # Ofcom Online Safety Act — n/a
    atrs_required: false           # Algorithmic Transparency Recording Standard — n/a (private sector)
    cma_watch: false               # CMA AI watch — n/a
    # EU AI Act (only if eu_nexus: true)
    eu_ai_act_role: na             # na if no EU nexus; otherwise provider | deployer | importer | distributor | authorized_rep | product_manufacturer
    eu_ai_act_role_basis: na
    eu_ai_act_tier: na             # na if no EU nexus; otherwise prohibited | high_risk | limited | minimal | gpai | gpai_systemic
    eu_ai_act_tier_basis: na
    # Assessment status
    obligations_assessed: false
    obligations_note: "UK: Art. 22 requires human intervention right, meaningful information, right to contest; Art. 35 DPIA to run; ICO explainability guidance applies [verify against current ICO AI guidance]"
    next_review: "2026-08-01"
    review_trigger: "on substantial modification or annually"
    created: "2026-05-18"
    updated: "2026-05-18"

Why this skill does NOT auto-derive obligations

The inventory stores flags and the basis for each. It does NOT contain a hardcoded flag → 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-uk:aia-generation for the formal impact assessment if needed.

This is deliberate:

• UK regulatory obligations are evolving — ICO guidance updates, Data (Use and Access) Act 2025 implementing provisions, sector regulator publications.
• EU AI Act mapping is complex and phasing in through 2027.
• Confident-and-wrong on a compliance obligation ends up in a board memo.
• The inventory is a registry for the solicitor. The solicitor 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.
• EU AI Act scope check. Before any EU AI Act analysis, confirm EU nexus. If none, skip the EU AI Act tier and mark eu_ai_act_tier: na. The EU AI Act is NOT UK domestic law.