How accountants and tax advisers can help SME clients start an EU AI Act inventory
Short answer: you do not need to become an AI lawyer. What many EU SMEs need first is a dated list of every AI tool they use, a quick screen for banned and high-risk uses, and a place to keep vendor answers and staff briefings. Accountants and tax advisers already sit in that conversation when they ask about software costs, payroll tools and customer systems. A 60-minute inventory workshop is often enough to start.
Why this lands with your clients now
Article 4 (AI literacy for staff who use AI) and Article 5 (banned practices) have applied since 2 February 2025. Transparency duties under Article 50 apply from 2 August 2026 for chatbots and AI-generated content that people might take as real. High-risk rules for many Annex III uses (for example recruitment and credit) were moved by the Digital Omnibus on AI. Clients who sell into or operate in the EU will be asked by customers, insurers and larger buyers whether they know which AI they use. Official text: Regulation (EU) 2024/1689 and Regulation (EU) 2026/1744.
What is in scope for a first workshop (and what is not)
| In scope for you | Hand to a lawyer or specialist |
|---|---|
| List every AI tool the client pays for or has switched on | Legal opinions on high-risk classification |
| Capture vendor name, purpose, owner and whether it talks to customers or staff | Conformity assessment or CE marking for high-risk systems |
| Flag hiring, credit, education, biometric or monitoring uses for follow-up | Contract redlines with AI vendors |
| Store vendor questionnaire replies and staff briefing dates | Representing the client before a market surveillance authority |
60-minute workshop agenda
- Minutes 0–10 — set the frame. Explain you are building a living list, not a compliance certificate. Show the official EUR-Lex links above. Agree who in the client firm owns the list after the call.
- Minutes 10–30 — inventory the tools. Walk SaaS invoices, browser extensions, Microsoft 365 / Google Workspace AI features, chatbots on the website, HR and accounting add-ons, and free personal ChatGPT or Claude accounts used for work. One row per system.
- Minutes 30–45 — screen. For each row: does it talk to people? Generate public content? Touch hiring, credit, education or biometrics? Anything that looks like social scoring or exploiting vulnerability (Article 5) goes to a lawyer the same week.
- Minutes 45–55 — evidence gaps. Which vendors have not answered the 12 deployer questions? Who on staff needs a short AI-literacy briefing (Article 4)?
- Minutes 55–60 — next review date. Book a 30-minute review in 90 days or when they buy a new AI tool, whichever is sooner.
Fields to capture per AI system
- Name and one-line purpose
- Internal owner (a person, not "IT")
- Vendor / product and model if known
- Role: usually deployer if they only use a vendor tool
- Who it affects: customers, staff, applicants, public
- Banned-practice screen (Article 5): no / not sure
- High-risk screen (Annex III / Annex I): no / possibly + which area
- Transparency triggers (Article 50): chatbot or generative content?
- Evidence links: vendor reply, briefing date, notice shown to users
- Status and next review date
A fuller field list for end clients is in the SME inventory template. For vendor questions see 12 questions to ask an AI vendor.
How to keep the list without a new IT project
A shared spreadsheet works. If the client wants each system, risk note and evidence date in one browser tool with no account and no upload, the EURO AI Register free edition covers up to 3 AI systems and 10 evidence records. A paid membership removes those limits. You can also refer clients and earn via the open affiliate programme on Gumroad (up to 50% of each referred sale; Gumroad pays partners directly). Neither tool is legal advice or proof of compliance.
Stay inside your professional rules. Do not claim the client is "EU AI Act compliant" after an inventory workshop. Do not invent certifications. Correct any error you spot: write to mininglife7@gmail.com.
Email you can send a client before the call
Subject: 60-minute AI tool list (EU AI Act starting point) Hi [Name], Several of our EU clients are being asked which AI tools they use. Before we talk about duties, we need a simple dated list. Please bring to our call: 1. Last 12 months of SaaS / software invoices 2. Any chatbot or AI writing tool on your website or in support 3. HR / recruitment / credit tools that use scoring or ranking 4. Names of staff who use ChatGPT, Copilot or similar for work We will fill one row per tool, flag anything that needs a lawyer, and set a review date. This is a record-keeping start, not a legal opinion. [Your name]
Free sample for your firm: run the EURO AI Register free edition on one internal AI tool first, then reuse the same fields with clients. Related: Article 4 literacy · Article 50 checklist.
Unadhi Guides are free, independent explainers. We correct errors as soon as we find them: write to mininglife7@gmail.com.