The AI Risk Register: A Starter Template

An AI risk register is simply a structured list of where AI is used, what could go wrong, and how you would know. It does not need to be elaborate — it needs to exist.

The columns that matter

Eight fields carry almost all of the value. Anything beyond them is refinement; anything short of them leaves a question you cannot answer when someone asks.

ColumnWhat it captures
SystemThe AI tool or model, named the way people actually refer to it.
OwnerThe person accountable — a name, not a department.
Use caseWhat it does, and whether it touches personal or regulated data.
RiskThe specific failure, written as cause → consequence.
LikelihoodLow / Medium / High. Judgement is fine; precision is not the point.
ImpactHow bad it is if it happens — to people first, then the organisation.
MitigationThe control that reduces it, stated as something someone does.
StatusOpen, mitigated, accepted — and the date it was last reviewed.

A worked example

One filled-in row is worth three pages of methodology. Here is what a real entry looks like:

FieldEntry
SystemAI chatbot for customer support
OwnerHead of CX
Use caseAnswers customer questions; handles personal data
RiskHallucinated answer given as fact → harm / liability
LikelihoodMedium
ImpactHigh
MitigationDisclose it is AI; limit to trained topics; human handoff; logging
StatusOpen — reviewed monthly

Note what the mitigation column does not say: “improve model accuracy”. Mitigations are actions with owners and evidence, not aspirations.

Five steps to stand one up

  1. Catalogue the tools. Every AI system in use, including the ones procurement never saw. A confidential, non-punitive survey will find more than an audit will.
  2. Assign ownership and document purpose. One named owner per system, and a plain sentence about what it is for.
  3. Estimate the risk. Likelihood and impact, agreed in a room, in an afternoon. Do not build a scoring model.
  4. Add controls for the high-risk rows. Start where the impact is highest; leave the low-risk rows documented and untouched.
  5. Review monthly. A short, recurring review — what changed, what is new, what can close.

The value is in the habit, not the tool

A spreadsheet reviewed every month beats a governance platform nobody opens. Start in whatever your organisation already uses, and only move when the spreadsheet genuinely stops working.

Three ways this goes wrong

  • It is built once. A register with no review date is an artefact, not a control. It ages badly and is worse than nothing in front of a regulator.
  • It only lists approved systems. If shadow AI is missing, the register describes the organisation you wish you had. Start there instead.
  • It is owned by the tooling team. Risk sits with the business owner of the use case. Engineering can maintain the entry; it cannot accept the risk.

Next: AI Governance for Non-Technical Leaders — where the register fits in the wider picture.