Building an AI Register for Your Department

The new CIO of a state rural-development department asked for a list of AI tools in production. She received three PowerPoints, a GeM invoice, and a rumour that a district collector had given a intern's ChatGPT password to the grievance cell. Two weeks later a newspaper asked how many citizen cases an algorithm had touched. The department could not say. The secretary asked why the CIO needed a month to count her own desks.

An AI register is not a European trophy and it is not a MeitY filing until someone issues one. It is an inventory: which workflows exist, on what basis, which model, where they run, who owns them. Without it you cannot classify risk, answer RTI, brief a board, or tell CAG which packets to expect. With it, every other artefact in this cluster has a home.

This is a template for CIOs. 16 August 2026. Not legal advice. Prcept will appear as a row if you buy us. We will not be the register.

What the register is not

It is not the EU AI Act database. India has not copied that law. Do not number your rows as if MeitY had issued risk classes. Your departmental scheme — citizen-facing, money, identity, internal — lives in a later article. The register only stores the class you chose.

It is not a model zoo. Weights without a workflow are a science project. Workflows without weights (a rules engine someone branded as AI) still belong if officers think an agent decides. Inventory the decision, not the branding.

It is not a substitute for the processor contract, the model card, or the case packet. It is the index of those things. When the index is empty, the rest is folklore.

Columns that earn their keep

Start with these. Add sector columns later. Do not start with a 40-column fantasy.

Column	Why it exists	Example
Workflow ID and name	Stable handle for CAG, [RTI](/blog/rti-requests-about-ai-decisions-be-ready), logs	RD-GRV-DRAFT-02
Purpose in one sentence	DPDP purpose limitation starts here	Draft replies to existing scheme FAQs
Lawful basis note	Consent, Section 7 legitimate use, or other — written, not implied	File 14/2026, DPO para 3
Model identity	Ties to the card and the hash you loaded	Family X, hash 9c2, card MC-14
Location	Runtime and log store, not a sales region	SDC cage B, no outbound; SIEM on SDC
Owner post	A human who can be transferred and still exist as a post	Director (IT) / DPO co-sign
Departmental risk class	Your scheme, not a fake MeitY class	Citizen-facing, no money
Status and sunset	Pilots that never die are production	Live; review 30 Nov 2026

Keep the working register in a place officers already treat as a record — eOffice, a numbered circular annex, a configuration-management DB you actually back up. A spreadsheet on a laptop is how the intern's ChatGPT row never appears.

How to find the rows nobody will volunteer

Ask finance for every invoice that mentions AI, LLM, copilot, bot or 'intelligent'. Ask NIC for every outbound allow-list exception. Ask the grievance cell what they paste into browsers. Ask districts, not only the secretariat. Give people two weeks of amnesty: declare the unofficial tool, get a row, get a decision to keep or kill. After the amnesty, unofficial agents are a conduct issue, not an innovation story.

A university or PSU should do the same for research GPUs that quietly sit on student records. The register is not only for the ministry website chatbot. It is for every workflow that can retrieve personal data or move a file.

Two secretaries, two inventories

Objections

Units say registration will slow innovation. Answer: unregistered production is not innovation. It is an unowned processor. Register in a day. Debate the sunset later.

Legal says a public register creates RTI risk. Answer: the agent already creates RTI risk. Section 4 prefers you admit what exists. Hiding the row does not hide the speaking order.

A vendor says their platform can be the register. Answer: they can feed it. They cannot own it. When the contract ends the register stays.

Leadership wants a blockchain register. Answer: no. A signed circular annex and a backed-up table will do. Spend the money on the amnesty.

A four-week playbook

• Week 1: issue the amnesty note. Open the column set. Name the owner post.
• Week 2: harvest invoices, allow-lists, and district rumours. Create rows, including 'to be killed'.
• Week 3: DPO co-signs lawful-basis and data-class columns. Kill what you will not stand behind.
• Week 4: publish the public extract for citizen-facing rows. Put the internal register on the Board pack and the internal-audit universe.

File note you can paste

Subject: Constitution of the departmental AI register.

With immediate effect, no software agent that retrieves departmental records or drafts official text shall run without a row on the AI register maintained by the CIO. Each row will state purpose, lawful-basis note, model identity, location of runtime and logs, owner post, departmental risk class, and sunset or review date. This is an internal control. It is not a claim that MeitY has mandated a public algorithm register.

A two-week declaration window is opened. After it closes, unregistered agents that touch official records will be treated as unauthorised processing. A public extract of citizen-facing rows will be prepared for Section 4. This note is not legal advice.

Keeping the register alive after the amnesty

A register that is updated only when a CIO is new is a census, not a control. Tie new rows to the change-advisory board: no production identity, no DNS name, no tool credential, without a row ID. Tie killed rows to an exit ticket: tenant deleted, keys rotated, public extract edited. The killed row stays on the internal register for the audit cycle. Erasing history is how shadow tools are reborn with new names.

Districts will invent local agents the secretariat never sees. Give collectors a one-line declaration form and a monthly reminder that unofficial public models on official records are unauthorised processing. You will not catch all of them. You will catch the ones that later become newspaper stories if you asked.

Universities should register research agents that sit on student or patient records even when the science budget paid for the GPU. The register is not an insult to research. It is how the registrar answers a parent and a regulator without calling a professor at midnight.

When a vendor is swapped, the row remains and the model identity changes. That is the point of a workflow-first inventory. If you delete the row and create a pretty new one, you lose the grievance history that still names the old ID. Change the hash. Keep the handle.

• Review sunsets on a standing first-Monday slot, not when a minister asks.
• If a row has no owner post because the person transferred, the row is amber the same day.
• Publish the public extract's last-updated date. A stale extract is a Section 4 failure you chose.

Informational field guidance for Indian public institutions. Confirm DPDP roles, RTI Section 4 practice and your secretariat instructions before you publish an extract.

How this survives CAG, RTI or the Board

“Building an AI Register for Your Department” is not a workshop slide. A P1 CIO/CTO will have to reconstruct a decision after the officer who clicked approve has been transferred. Write the artefact that lets a stranger replay the case: the log fields, the approval, the override, the register row.

If you cannot list the agents that already draft for your officers, you do not have a programme. You have hobbies. The register is the one-page inventory a secretary, a DPO and a CAG party can share. India AI Governance Guidelines (November 2025) are guidelines, not a statute. DPDP still allocates fiduciary duty. Delegation of Financial Powers still allocates who may spend. Do not hide those instruments behind the word governance.

If you cannot show who acted, on which purpose, with which data class, and who could have refused, you do not have accountability. You have a chatbot with a charter PDF.

• Name the owner of “AI inventory register government” inside the department, not the vendor.
• Keep CERT-In-relevant logs in India for the required period.
• Store overrides with a reason an auditor can read.
• Put the workflow on the AI register before it touches a citizen.

Close this loop before the next CAB

Put “Building an AI Register for Your Department” on the next change-advisory or bid-opening agenda as a single line item with an owner. If it cannot earn a line item, it will not earn a control. The owner should be a P1 CIO/CTO, not “the vendor.”

Revisit the item when the model, the GeM term, the region, or the SI changes. “AI inventory register government” is not a one-time workshop. It is a watch item. Date the last check. Unsigned watch items are souvenirs.