Is Excel-with-AI-features an AI system?
Classic spreadsheet formulas are not an AI system.
Drafted with AI help and checked against the official EU text before publishing.
Classic spreadsheet formulas are not an AI system. They follow rules a person wrote. An assistant inside Excel that infers what to write, predict or recommend from your prompt usually is — use the Article 3(1) test, not the product name on the box.
Recital 12 says the definition should not cover systems based solely on rules defined by people to execute operations automatically.
An assistant inside Excel that infers what to write, predict or recommend from your prompt usually is an AI system. List the features you actually switch on. If only the formula engine is in use, treat it as ordinary software. If staff chat with an assistant in the sheet, treat that assistant as an AI system.
This is general information, not legal advice.
What the law actually says
"‘AI system’ means a machine-based system that is designed to operate with varying levels of autonomy and that may exhibit adaptiveness after deployment, and that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments;"— EU AI Act, Article 3(1) (Regulation (EU) 2024/1689) · eur-lex.europa.eu
"standard spreadsheet software applications which do not incorporate AI enabled functionalities"— European Commission, Guidelines on the definition of an artificial intelligence system, C(2025) 5053 final, 29 July 2025, paragraph 46 · ai-act-service-desk.ec.europa.eu
In plain words
- SUM, VLOOKUP and a recorded macro execute rules a person defined. Recital 12 says the definition "should not cover systems that are based on the rules defined solely by natural persons to automatically execute operations".
- The Commission put it beyond doubt in its own guidelines: "standard spreadsheet software applications which do not incorporate AI enabled functionalities" are outside the definition.
- Recital 12 also names the test in one line: "A key characteristic of AI systems is their capability to infer."
- Copilot-style features that infer the next sentence, a forecast, or a suggested formula from a prompt sit inside Article 3(1).
- You do not need a second definition for a shop. List the features you actually switch on.
- If only the formula engine is in use, treat it as ordinary software. If staff chat with an assistant in the sheet, treat that assistant as an AI system.
- Will look for signs of AI use in the folders you choose, and write them down for you.
- Will write a plain-language readiness report. No evidence reads "Not assessed", never a green tick.
- Will run as a free Windows program on your own computer and send nothing from it.
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