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AI register example: what a completed register looks like

Five rows from a fictional AI register, from a free ChatGPT account to an HR screening tool, with the reason for every column and what to fill in.

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Quick answer

A completed AI register has one row per application. Each row holds the tool and its vendor, the purpose, an owner in the business, which data may go in and which may not, the outcome of the risk assessment, the organisation's decision (allowed, limited use, no decision yet or not allowed), the date of that decision and when it comes up for review. The example below has five rows: a free ChatGPT account, Microsoft 365 Copilot, Perplexity, a meeting transcription tool and an HR screening tool. Two rows are still marked "No decision yet". Those are not gaps in the register but its most honest rows: each of those tools has been seen and not yet assessed.

01

One row per application, with the tool as a property of that row

02

The data and decision columns do the work; the others make the decision traceable

03

A tool that has been seen but not assessed goes in as "No decision yet", dated from when it was first seen

04

A free account nobody ever bought belongs in the register as soon as it is used

05

"Not allowed" without an alternative is a wish, not a decision

The board secretary of a housing association asks the privacy officer whether the AI register is finished. She opens the file: nine columns, five rows, two of them marked "No decision yet". She says yes, and that is the right answer.

An AI register is finished once every row has an owner, a decision and a review date, and once the tools that have been seen but not yet assessed are in it too. The register below is fictional, but the rows will look familiar to almost any organisation. What a register is and why you keep one is covered in our guide to the AI register. This article shows what one looks like once it is filled in.

What does a completed AI register look like?

Five rows, one per application. The risk outcomes are examples: yours depend on the account type, the data that goes in and what the vendor's terms say at the time.

ApplicationVendorPurposeOwnerDataRisk assessmentDecisionDateReview
ChatGPT, free accountOpenAI, USNo defined purpose; noticed in useCISO, for the decisionNone. Personal accounts may use input for training; no data processing agreement (DPA)High, 3 March 2026, CISONot allowed; alternative: Microsoft 365 Copilot3 March 2026March 2027, or earlier if the terms change
Microsoft 365 CopilotMicrosoft, USDrafting and summarising in Word, Outlook and TeamsHead of OperationsInternal documents and personal data within the user's own permissions; no special-category dataMedium, 17 February 2026, CISO with DPO; DPIA attachedAllowed17 February 2026February 2027, or earlier if new features are added
PerplexityPerplexity AI, USNot yet known; noticed in useNot yet assignedUntil the decision: public information onlyNot yet assessedNo decision yet14 May 2026, first sightingAssessment scheduled, June 2026
Meeting transcription toolEuropean vendor, processing in GermanyRecording and summarising internal meetingsTeam lead, SecretariatVoices and names of participants; no conversations with tenants or applicantsMedium, 9 April 2026, DPO; DPA signed, recordings kept 30 daysLimited use: internal meetings only, participants informed in advance9 April 2026April 2027, or earlier after a vendor incident
HR screening toolDutch vendorPre-sorting applications against job requirementsHead of HRCVs and cover lettersUnder assessment; high-risk under Annex III of the AI Act, DPIA in progressNo decision yet2 June 2026, requestedAfter the DPIA, and in any case before 2 December 2027

Why is each column there?

Application and vendor. A row is about an application, not a product. Copilot for memos and Copilot for interview notes in HR are two rows with the same vendor. The vendor's country is there because it determines which agreement you need and which rules apply.

Purpose. One sentence. "No defined purpose" is an answer too, and a telling one: the tool is in use and nobody has written down what for. That alone is a reason to take a decision.

Owner. Someone in the business: the role that uses the application, can answer the assessment questions and drives the review. For a tool that is not allowed, the owner is whoever took the decision. Who holds which role is set out in our article on who is responsible for the AI register.

Data. What may go in, and what explicitly may not. This is the column where the risk lives. The same transcription tool is one thing in an internal meeting and another in a conversation with a tenant about arrears.

Risk assessment. The outcome, the date and who did it. A risk band is advice alongside the decision, not the decision itself; two tools with the same outcome can rightly end up with different statuses. Our guide to assessing the risk of an AI tool explains how to reach the outcome.

Decision. One of four values, and more than the word alone. "Limited use" carries its condition; "Not allowed" carries its alternative. Our article on the four statuses for AI tools explains why two values are too few.

Date and review. An undated decision cannot be defended. A decision without a review date ages unnoticed: the vendor's terms change, the tool gains a feature that reads documents and the row stays green.

Why are two rows marked "No decision yet"?

Because it is true, and because otherwise the register only describes what somebody once reported.

The Perplexity row appeared when the association first looked at which AI services were being opened in its browsers. Nobody had requested the tool and nobody did anything wrong, because nothing had been decided. The tool got a row with the date of its first sighting, an interim instruction and an assessment date. That took two minutes, and the tool has been visible ever since.

The HR screening tool is marked "No decision yet" for a different reason. HR requested it, the assessment is under way and the outcome is not a formality: a system that filters applications falls under Annex III of the AI Act, with the deployer duties of Article 26 applying from 2 December 2027. The EU AI Act for employers explains what that means for an employer. While the DPIA is running, "No decision yet" is the only accurate status.

Which row is missing from most registers?

The first one. A free ChatGPT account was never procured and does not appear on any invoice or purchasing list. Yet in many organisations it is the most-used AI tool. A register built from purchasing records misses it, and so misses exactly the row where the decision matters most. Our comparison of free and business AI accounts explains why the account type matters more than the tool.

Note how the decision on that row is written: "Not allowed", with an alternative next to it. Without the alternative, "Not allowed" is a wish rather than a decision, and use simply moves to people's phones.

BeeSensible connects a catalogue of over 1,000 AI tools to the use observed in the organisation: only the domain of an opened AI tool, at most once per day per device, with no user ID and no content. So a tool nobody reported shows up in the Inbox on its own, marked "No decision yet", and an administrator records the decision. The AI register page explains how that works.

AI register
AllowedUnder reviewNot allowedAll tools
Search by tool, vendor, domain or former name…
1,012 tools
DeepSeek
Critical · 90/100
Not allowed
Otter.aiNew
High · 68/100
No decision yet
Grok
High · 67/100
Not allowed
ChatGPT
High · 62/100
Allowed
Perplexity
Medium · 55/100
No decision yet
HeyGen
Medium · 53/100
No decision yet

Every tool, scored for risk

Over 1,000 AI tools, each scored from Low to Critical. Nothing is approved or blocked until someone decides.

More about AI Governance

The register is one part of the wider work, from seeing what is used to showing that the policy is applied. The overview page for AI governance covers the rest.

Compare your own register with this example and look for the row for the free account nobody ever requested. If it is not there, that is where you start.

FAQ

Common questions

How many columns does an AI register need?

In practice, nine do the work: application, vendor, purpose, owner, data, risk assessment, decision, date and review. More columns do not make the register better; they just stay empty. With fewer, the register fails the first question from an auditor or a colleague: who decided this and when, and can I put customer data in it?

Does a tool nobody requested belong in the register?

Yes, as soon as it is used. The register describes the organisation's AI use, not its purchasing history. A tool that has been noticed but not assessed gets a row marked "No decision yet", with the date it was first seen and an interim instruction: public information only. Without that row, everyone decides for themselves what is acceptable.

Who is the owner of a tool that is not allowed?

The role that took the decision and revisits it at review time, usually the CISO or whoever owns the register as a whole. For applications in use, the owner is in the business: the role that uses the tool and can explain what it is used for and with which data.

Would the risk assessments in the example come out the same for us?

Not necessarily. The outcome depends on the account type, the data that goes in and the vendor's terms at that moment. A free ChatGPT account and a ChatGPT Business workspace are two rows with two outcomes. Borrow the columns, not the entries.

How often do you revisit the review column?

Set a period, usually a year, and name the events that bring the review forward: new terms, a new feature from the vendor, an acquisition, an incident or a new use inside the organisation. The period is the minimum; the events are what keep the register accurate.

Portrait of Rens Timmermans from BeeSensible

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