The Evidence Brief · Issue 2
The AI inventory you think you have
Most AI inventories capture what someone submitted, not what is actually in use. A practical look at where inventories go stale and how to test whether yours is complete.

Almost every organization I talk with now has an AI inventory. Far fewer could tell you how they know it is complete. An inventory is not a list of AI in use. It is a list of AI that someone told you about, and those are not the same thing.
What I’m seeing
I have built an AI use-case intake process and an inventory of more than 50 use cases mapped to NIST AI RMF and ISO/IEC 42001. The most useful lesson from that work was not about the mapping. It was about the front door. An inventory fills up through intake, and intake only catches what people think to submit.
That leaves predictable blind spots:
- AI that arrived inside existing software. A vendor adds a summarization feature or an AI assistant to a platform you already license. No one filed a request, because no one bought anything new.
- Use that grew past its approval. A tool approved for drafting internal notes is now drafting customer communications. The inventory still shows the original purpose.
- Experiments that quietly became production. A pilot ran, people liked it, and it kept running. The inventory still says “pilot,” or it never listed the pilot at all.
- Entries that are present but hollow. The use case is listed, but the owner left the company, the risk rating is a placeholder, and the last review date is blank.
None of this means the program failed. It means the inventory reflects a moment, and the organization kept moving after that moment.
Why it matters
The inventory is the foundation for almost everything else in AI governance. Risk ratings, monitoring, vendor reviews, policy attestations, and board reporting all assume the inventory is right. If a use case is missing, every downstream control misses it too.
The frameworks make this dependency clear. NIST AI RMF starts with understanding context and mapping AI systems before you can measure or manage their risk. ISO/IEC 42001 expects an organization to define the scope of its AI management system and know which AI systems fall inside it. Neither works from a partial list.
There is also a reporting risk. Imagine a leader telling the board, “we have 40 AI use cases under governance.” The board hears “we have 40 AI use cases.” If the real number is meaningfully higher, the gap is not just an operational issue. It is a statement that turned out to be inaccurate.
So the question is not “do we have an inventory?” It is “what sources, other than intake, confirm the inventory is complete?”
What to do this week
- Reconcile the inventory against one independent source. Pick a source that does not depend on self-reporting: your vendor or contract list, software license records, network or browser traffic for known AI services, or expense reports. Compare it to the inventory and list what appears in one but not the other.
- Ask your top vendors a direct question. For the handful of platforms your teams use most, ask the vendor in writing which AI features are currently enabled in your environment and which are on by default. Add anything you did not already know about to intake.
- Run a currency check on ten entries. Pull ten inventory records at random. For each, confirm the owner is still in the role, the stated purpose matches actual use, and the last review date is within your policy. Note how many pass all three checks. That ratio is a more honest measure of inventory quality than the total count.
A question for your next meeting
“Other than people submitting requests, how do we find AI that is already in use here?”
If the only answer is intake, you have a list of what was declared, and the next step is building a way to find what was not.
Until next time,
Nath
The Evidence Brief shares practical perspectives on technology risk, audit, and AI governance. It is general information, not legal or regulatory advice.
