Where is AI being used in your company?
A list of licences shows what was bought. It does not show where AI runs in each function, what it does there, or what sits inside supplier software.
ASIC puts the question first in its list for licensees: “Where is AI currently being used in your business?” The AICD’s 2026 guide for directors says an AI inventory should track every approved AI system and be updated regularly. The answer starts with each function head, not the IT asset list.
What do regulators and director bodies ask?
ASIC, REP 798
What it asksWhere AI is currently used in the business. The first of eleven governance questions for licensees
DateOctober 2024
APRA, letter to industry on AI
What it asksAn inventory of AI tooling and AI use cases, as a minimum governance arrangement for APRA-regulated entities
DateApril 2026
AICD, A Director's Guide to AI Governance (v2)
What it asksAn AI inventory or register that tracks all approved AI systems, with a process to update it regularly
DateJune 2026
Institute of Directors (UK), AI Governance in the Boardroom
What it asksWhether the board has a real-time inventory of AI in use, including AI embedded in third-party and supplier tools
DateJune 2025
ASIC also asks whether governance arrangements lead or lag the use of AI.
What does an asset list miss?
Tools staff use without approval.
AI built into supplier and third-party software.
What each tool does inside the workflow, and who owns it.
What it costs by function, rather than by contract.
The AICD guide flags the first two: AI embedded in third-party products, and staff using AI tools on a shadow basis.
What should an AI inventory hold?
- Function
- Ownership sits with a function, not a vendor.
- What runs
- The tool, or the supplier system it sits inside.
- What it does
- The workflow it touches, in plain words.
- Owner
- One named person per entry.
- Annual cost
- Read by function, so it can be set against the outcome.
- Outcome measured
- Whether anyone reports what it returns.
- Last reviewed
- The AICD guide calls for a process to update the register regularly.
Where does the Automation Report fit?
The Automation Report is not an inventory.
It reads how far AI and automation reach into each function, from that function's head: Technology, Compliance and Risk, Operations, Finance, Growth and Revenue, and Customer Success, plus the CEO. Workflows reads the share of each function's core workflows that run with an AI or automation component. Tools reads how widely and how deeply AI and automation tools are adopted.
For each reading, the report states the gap between the CEO's reading and the function heads'. Quarterly Reviews at months 3, 6 and 9 show indicative movement against the issued report.
The gap, per dimension
Frequently asked questions
- What is an AI inventory?
- A register of the AI systems and tools a company runs, with what each does, who owns it and what it costs. The AICD guide describes it as the board's view of AI use across the organisation.
- Does ASIC require an AI inventory?
- REP 798 is a review report, not a rule. It sets out questions for licensees. The first asks where AI is currently used in the business, and the follow-up asks whether the licensee has an AI inventory that is adequately maintained. Whether a specific obligation applies is a question for the company's counsel.
- Does APRA expect an AI inventory?
- For APRA-regulated entities, yes. Its April 2026 letter to industry lists an inventory of AI tooling and AI use cases among the minimum governance arrangements it expects.
- Should the inventory include AI inside supplier software?
- Yes. The UK Institute of Directors asks boards whether their inventory includes AI embedded in third-party and supplier tools. APRA also expects regulated entities to map their AI supply chain, including third-party and fourth-party dependencies.
- How often should the inventory be updated?
- On a set cycle. The AICD guide calls for a process to update the register regularly, and the IoD asks for a real-time inventory. The Automation Report reads where AI runs at issue, with Quarterly Reviews at months 3, 6 and 9 and an Annual Report at 12 months.
- Who should keep the inventory?
- Each function head for their own function, with one named owner for the register as a whole.
Sources
ASIC, REP 798 Beware the gap: Governance arrangements in the face of AI innovation, October 2024.
APRA, Letter to Industry on Artificial Intelligence (AI), 30 April 2026.
AICD and UTS Human Technology Institute, A Director's Guide to AI Governance, Version 2, June 2026.
Institute of Directors, AI Governance in the Boardroom, June 2025.