Consider an $N$-dimensional quantum system with the Hamiltonian $$ H = \left[ \begin{matrix} E_{1} & 0 & \cdots & 0 \\ 0 & E_{2} & \cdots & 0 \\ 0 & 0 & \cdots & 0 \\ \vdots & \vdots & \ddots & \vdots \\ 0 & 0 & \cdots & E_{N} \end{matrix} \right] \ . $$ $H$ generates translations in time $t$, such that $|\Psi(t_2)\rangle = e^{- i H (t_2-t_{1}) } |\Psi(t_1) \rangle$. This is a bit of strange question but does there exist an action $S$ corresponding to the above system? In field theory the action is a scalar, so this seems unlikely to me (I don't know how to build scalars out matrices)...
In the case that there is not, is there a way to see this system as a limit of a some $S$ (possibly built out of fields)?