AI inventory for the EU AI Act: when a spreadsheet is enough, and when it is not
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Short answer: For one or two AI tools, none of them high-risk, a spreadsheet with one row per system, its classification, the article and the date you decided is a fair record — even a paid competitor, CompliPath, says so on its own page, and Crux Digits calls a spreadsheet “a legitimate starting point”. A spreadsheet starts to break when the law changes under it (Regulation (EU) 2026/1744 replaced Article 4 and moved the high-risk dates), when you need evidence linked to each duty, or when a customer asks you to show rather than tell. Free option either way: copy our column list below, or use EURO AI Register free for up to 10 AI systems.
Why this matters now (dates (source: Regulation (EU) 2024/1689))
- Article 4 AI literacy has applied since 2 February 2025 to providers and deployers, whatever the risk level. As replaced by Regulation (EU) 2026/1744, it asks organisations to take measures to support the AI literacy of their staff; it does not require them to guarantee a specific level for any individual. The European Commission's Q&A says there is no need for a certificate: an internal record of trainings or guidance is enough, and national authorities supervise and enforce from August 2026 (Commission AI literacy Q&A).
- Article 50 transparency duties (for example, telling people they are talking to a chatbot) apply from 2 August 2026 (Regulation (EU) 2024/1689).
- High-risk rules were moved by the Digital Omnibus on AI, Regulation (EU) 2026/1744: Annex III uses (such as recruitment and credit scoring) from 2 December 2027, and AI in regulated products (Annex I) from 2 August 2028.
Your three honest options
| Your own spreadsheet | EU AI Act Readiness Kit (Excel) | EURO AI Register (browser) | |
|---|---|---|---|
| Price | Free | $29 once, 14-day refund | Free up to 10 systems; $19/month or $190/year unlimited |
| Setup | You design columns and rules | Drop-downs for role, Article 5 check, Annex III areas, transparency triggers; formula flags a starting point | Fixed screening questions with the article behind each result |
| Dates and law changes | You track them | Obligations map with a “status today” column; rules checked 11 Oct 2026 | Duties by role with dates; members get rule updates and a monthly change note |
| Evidence | Links you paste | Risk register, 90-day roadmap, AI literacy log | Evidence log with file name, size and SHA-256 fingerprint |
| Policy | Write your own | AI Literacy and Acceptable Use Policy template (Word) | AI use policy generator based on the Kit's template |
| Best for | 1–2 tools, nothing high-risk | Teams who live in Excel | Teams who want guided screening without uploading data |
Free gift: the column list for your own AI inventory
Copy this header row into a new sheet. It mirrors what the Act and the Commission's literacy Q&A ask you to know.
Rules of thumb: one row per system as used (the same tool for two purposes can be two rows), record who decided and when, and re-check every row when the law changes — as it did on 27 July 2026, when Regulation (EU) 2026/1744 entered into force.
Signs you have outgrown the spreadsheet
- More than a handful of AI tools across teams, and nobody is sure the sheet is current.
- A customer or supervisor asks for the evidence behind a row, not just the row.
- A system might touch hiring, credit, education or biometrics (Annex III) — then also talk to a lawyer.
Start free: your AI inventory and Article 4 record in 10 minutes
Free for up to 10 AI systems · membership $19/month or $190/year · 14-day money-back
EURO AI Register runs in your browser with no account and no upload; what you enter stays on your device. The free edition covers your first 10 AI systems and 10 evidence records, including the printable Article 4 AI-literacy record. Membership adds unlimited systems and evidence, rule updates when the law or official guidance changes, a short monthly “What changed in the EU AI Act” note, email help, and the $29 EU AI Act Readiness Kit included. Honest limits: single user on one device (teams share JSON backups), no DPIA generator, no AI copilot, no integrations. Disclosure: Unadhi product. New product, no reviews yet.
Open the free register (no account) Membership on Gumroad — $19/month
Accountant or tax adviser with SME clients? See the client AI inventory guide for accountants and the partner line at the top of this page.
Prefer Excel? The EU AI Act Readiness Kit is $29 with a 14-day refund (Unadhi product).
Frequently asked questions
Is a spreadsheet enough for an EU AI Act AI inventory?
For one or two AI systems that are not high-risk, yes: a spreadsheet with the classification, the article relied on and the decision date is a fair record. Paid vendor CompliPath and consultancy Crux Digits both say this on their own public pages, read on 14 Oct 2026.
What columns should an AI inventory have for the EU AI Act?
The Act sets no single template for deployers. Useful columns: system name, vendor, purpose, owner, your role, the Article 5 banned-practice check, Annex III and Annex I checks, Article 50 transparency trigger, decision and date, who decided, literacy measures taken, evidence link and next review date.
When have I outgrown a spreadsheet for AI Act records?
Signs include more than a handful of AI tools across teams with nobody sure the sheet is current, a customer or supervisor asking for the evidence behind a row, or a system that may touch hiring, credit, education or biometrics under Annex III. In that last case, also talk to a lawyer.
What does EURO AI Register cost compared with a spreadsheet?
A spreadsheet is free but you track rules and dates yourself. EURO AI Register is free for up to 10 AI systems, including the printable Article 4 literacy record; beyond that it is $19 a month or $190 a year flat, with unlimited systems. It adds screening questions with article references, duties by role with dates and an evidence log with file fingerprints.
Do I need a certificate to prove Article 4 AI literacy?
No. The European Commission's AI literacy Q&A says there is no need for a certificate; an internal record of trainings or guidance is enough. As replaced by Regulation (EU) 2026/1744, Article 4 asks organisations to take measures to support staff AI literacy, not to guarantee a specific level for each person.
Not legal advice. EURO AI Register and the Readiness Kit are record-keeping aids, not proof of compliance, not an audit and not a conformity assessment; the AI Act has no organisation-wide seal a tool can give you. If a system may be banned or high-risk, have a qualified lawyer review it. Unadhi is not affiliated with the EU or any EU authority. Competitor prices and plans change; re-check their pricing pages before you decide. Spotted an error about any product on this page, including ours? Write to mininglife7@gmail.com and we correct it.
Sources
- CompliPath: EU AI Act compliance software for SMEs (“When is a spreadsheet enough?”) — https://www.complipath.io/eu-ai-act-compliance-software-sme/ (read 14 Oct 2026)
- Crux Digits: EU AI Act consultants for SMEs (“A spreadsheet is a legitimate starting point”) — https://cruxdigits.nl/eu-ai-act-consultants-sme/ (read 14 Oct 2026)
- EU AI Act Readiness Kit on Gumroad — https://mininglife1.gumroad.com/l/eu-ai-act-readiness-kit (read 14 Oct 2026)
- Regulation (EU) 2026/1744 (Digital Omnibus on AI), EUR-Lex — https://eur-lex.europa.eu/eli/reg/2026/1744/oj (read 14 Oct 2026)
- Regulation (EU) 2024/1689 (AI Act), EUR-Lex — https://eur-lex.europa.eu/eli/reg/2024/1689/oj (read 14 Oct 2026)
- European Commission, AI literacy Q&A — https://digital-strategy.ec.europa.eu/en/faqs/ai-literacy-questions-answers (read 14 Oct 2026)
- EURO AI Register (free edition, plans) — https://unadhi.com/register/ (read 14 Oct 2026)
- EURO AI Register membership on Gumroad (price, refund, limits) — https://mininglife1.gumroad.com/l/euro-ai-register (read 14 Oct 2026)
- Related Unadhi guides: EU AI Act compliance tools for small businesses (roundup) · AI inventory template · Article 4 AI literacy for small businesses
Unadhi Guides are free, independent explainers. We correct errors as soon as we find them: write to mininglife7@gmail.com.