Fundamental Rights Impact Assessment (FRIA)

Fundamental rights assessment for high-risk AI systems

Requirement

The FRIA duty applies under the conditions of Article 27 to public-law deployers and certain private entities providing public services, and to deployers of the systems referred to in Annex III points 5(b) and 5(c). The core Annex III obligations generally apply from 2 December 2027.

1. General Information

1.1Name of the AI system

1.2Provider / developer

1.3Name deployer (your organization)

1.4Date of this assessment

1.5Assessor(s)

1.6Intended purpose

1.7Target group / affected persons

2. Purpose and Context

2.1What problem does the AI system solve?

2.2Why is AI needed (instead of a non-AI solution)?

2.3What decisions are supported or automated?

2.4How many people are expected to be affected?

2.5In which geographic areas will the system be deployed?

3. Fundamental Rights Assessment

Assess the potential impact of the AI system for each fundamental right.

Human dignity (Art. 1 EU Charter)

Can the system affect human dignity?

E.g. reducing people to data, discriminatory treatment, or violation of personal integrity.

Privacy & data protection (Art. 7-8)

Does the system process personal data? What risks exist?

E.g. unauthorized access, purpose limitation, retention periods, data subject rights.

Non-discrimination (Art. 21)

Can the system lead to discrimination?

E.g. based on race, gender, age, disability, religion, sexual orientation.

Equality before the law (Art. 20)

Are persons treated equally by the system?

E.g. consistent decision-making, no arbitrariness.

Effective legal remedy (Art. 47)

Can affected persons effectively object?

E.g. possibility of human review, appeal and objection options.

Freedom of expression (Art. 11)

Does the system affect free expression?

E.g. content moderation, recommendation algorithms, censorship.

Access to services (Art. 36)

Can the system limit access to essential services?

E.g. healthcare, education, social security, financial services.

4. Vulnerable Groups

4.1Are vulnerable groups affected? (children, elderly, people with disabilities, minorities)

4.2What additional protection measures are needed for these groups?

4.3Are certain groups disproportionately affected?

5. Risk Mitigation

5.1What measures have been taken to limit identified risks?

5.2What technical safeguards are built in?

5.3How is human oversight organized?

5.4What residual risks remain after mitigation?

6. Conclusion and Decision

6.1Overall risk assessment (low/medium/high)

6.2Is deployment of the AI system proportional given the risks?

6.3Recommendation: proceed / adjust / do not deploy

6.4Motivation for the decision

6.5Date of next review

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What is a FRIA? (Glossary)

Definition, Article 27 explained, a concrete example, and common misconceptions.

FRIA template explained (Article 27)

Background article for this template: who must perform a FRIA and what it must contain.

DPIA vs FRIA: practical comparison

When you need both and how to use your DPIA as a starting point.

Disclaimer: This template is a compliance tool and not legal advice. Consult a lawyer for specific situations.

Based on Article 27 of Regulation (EU) 2024/1689, as amended by Regulation (EU) 2026/1744.

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