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EU AI Act Fundamental Rights Impact Assessment Template (Article 27)

FRIA for deployers of high-risk AI under EU AI Act Article 27: processes, affected groups, risks, oversight, notification

AI और डेटापूर्णRegulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744, Article 27actfria
एडिटर में खोलें.md डाउनलोड करें

उपयोग कैसे करें: Use it if you are a public body, a private provider of public services, or a deployer of credit-scoring or life and health insurance pricing AI. Confirm applicability in section 1, then answer the six Article 27(1) elements before first use. The main pitfall is duplicating the DPIA instead of cross-referencing it, or forgetting to notify the market surveillance authority.

प्रीव्यू

Fundamental Rights Impact Assessment: [High-risk AI system] at [Deployer]

Fundamental rights impact assessment (FRIA) for a deployer of a high-risk AI system, organised on Article 27 of the EU Artificial Intelligence Act (Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744, the Digital Omnibus on AI). It records the deployer's processes, the period and frequency of use, the people affected, the specific risks of harm, human oversight, the measures if risks materialise, the notification to the market surveillance authority and the link to the DPIA. Replace every [bracketed] value and every row marked Example. Under the amended Article 113, the high-risk obligations in Chapter III Sections 1 to 3, which include Article 27, apply from 2 December 2027 for Article 6(2) (Annex III) systems, the only systems Article 27 covers (2 August 2028 for Annex I systems); check the consolidated text. This is a documentation format, not legal advice.

Document control

FieldValue
Document ID[FRIA-001]
Deployer[Legal name, address]
Deployer category[Body governed by public law / Private entity providing public services / Deployer of an Annex III point 5(b) or 5(c) system]
High-risk AI system[Name, version]
Provider[Provider name, contact]
EU database registration (if applicable)[Reference]
Version[0.1]
Status[Draft / In review / Approved / Notified / Superseded]
Owner[@fria-owner]
Assessment team[@legal], [@dpo], [@business-owner], [@it-lead], [@equality-officer]
Last updatedYYYY-MM-DD
Date of first useYYYY-MM-DD

Approvals

RoleNameDecisionDate
Business process owner[@name][Approve / Approve with conditions / Reject]YYYY-MM-DD
Data protection officer[@name][Opinion]YYYY-MM-DD
Legal counsel[@name][Decision]YYYY-MM-DD
Senior accountable officer[@name][Decision]YYYY-MM-DD

Revision history

VersionDateAuthorChange summary
0.1YYYY-MM-DD[@name]First draft
1.0YYYY-MM-DD[@name]Example: Approved and notified to the market surveillance authority
1.1YYYY-MM-DD[@name]Example: Updated after extending use to a second district (element (b) and (c) changed)

Contents

1. Applicability and scope

1.1 System classification

QuestionAnswerEvidence
Is the system high-risk under Article 6(2) (an Annex III use case)?[Yes / No]Example: Annex III point 5(a): eligibility for essential public assistance benefits; provider's declaration of conformity
Is it in Annex III point 2 (critical infrastructure)?[Yes / No]Article 27 does not apply to point 2 systems
Is the system used in line with the provider's intended purpose?[Yes / No]Instructions for use, section [x]

1.2 Deployer applicability

ConditionApplies?
Deployer is a body governed by public law[Yes / No]
Deployer is a private entity providing public services[Yes / No]
System is an Annex III point 5(b) system (creditworthiness or credit scoring of natural persons, other than fraud detection)[Yes / No]
System is an Annex III point 5(c) system (risk assessment and pricing for life and health insurance)[Yes / No]

Conclusion: [Example: Article 27 applies. The deployer is a municipality (body governed by public law) using an Annex III point 5(a) system.]

1.3 Reliance on earlier assessments

[State whether a previous FRIA or an impact assessment by the provider is relied on for similar cases, and which parts.] Example: No prior FRIA exists. The provider's fundamental rights considerations in its instructions for use (section 7) are used as input to section 3.4.

2. Information from the provider

Item from instructions for useSummaryGap or question to provider
Intended purposeExample: Flags applications for manual verificationNone
Accuracy and known limitationsExample: Precision 0.71 for "high-risk" flag; lower for applicants under 25Request subgroup data by nationality
Foreseeable risks to fundamental rightsExample: False flags delay benefitsNone
Human oversight measuresExample: Flags must be reviewed by trained staff; no automatic refusalNone
Input data specificationsExample: Application form fields 1 to 42Clarify handling of missing income data
LoggingExample: Logs retained 6 months by providerDeployer retention to be aligned

3. Assessment elements (Article 27(1))

3.1 (a) Description of the deployer's processes using the system

[Describe the business process, where the system sits in it, and the decisions it informs, in line with its intended purpose.]

Example: The Social Services department processes about 14,000 applications per year for housing assistance. After an application is submitted, the system scores it for the likelihood of incomplete or inconsistent information. Applications scored above 0.6 are routed to a verification team; all others go to standard processing. The system does not approve or refuse applications.

3.2 (b) Period and frequency of use

ItemValue
Start dateExample: YYYY-MM-DD
Intended periodExample: 24 months, then review
FrequencyExample: Every new application; about 55 per working day
Operating hoursExample: Batch every hour, 07:00 to 19:00

3.3 (c) Categories of natural persons and groups likely to be affected

IDCategoryEstimated number per yearVulnerability factors
AP-01Example: Applicants for housing assistance14,000Low income, possible disability, limited language skills
AP-02Example: Household members including children22,000Children; dependants
AP-03Example: Applicants with recent migration history2,500Non-standard documentation
AP-04Example: Case officers and verification staff60Workload; reliance on tool

3.4 (d) Specific risks of harm to those persons or groups

IDRisk of harmGroupsRights concernedSeverity (1 to 5)Likelihood (1 to 5)Rating
FR-01Example: Higher false flag rate for applicants with foreign documents, delaying supportAP-03, AP-02Non-discrimination; social security and social assistance4312
FR-02Example: Applicants not told that a system was used and cannot contest itAP-01Good administration; effective remedy339
FR-03Example: Excessive data use beyond what the process needsAP-01, AP-02Private life; protection of personal data326
FR-04Example: Delays affecting children's housing stabilityAP-02Rights of the child428
FR-05Example: Staff treat flags as findings of fraudAP-01Presumption of good faith; dignity339

Ratings are severity times likelihood: 1 to 4 low, 5 to 9 medium, 10 to 15 high, 16 to 25 very high.

3.5 (e) Human oversight measures

[Describe the oversight measures implemented according to the provider's instructions for use.]

MeasureWhoCompetence and authorityEvidence
Example: Every flagged application reviewed by a verification officer before any request to the applicantVerification team1-day training on the system's limitations; authority to dismiss flagsTraining records
Example: Flag shown with top contributing factors, never as "fraud"Interfacen/aScreen design
Example: Weekly sample of 50 non-flagged applications reviewedTeam leadAuthority to suspend the systemSample log
Example: Monthly monitoring of flag rate by groupData analystReports to steering groupDashboard
Example: Ability to stop use and revert to manual triageHead of serviceDocumented in runbookRunbook

3.6 (f) Measures if the risks materialise

RiskDetectionResponseOwner
FR-01Flag rate for AP-03 more than 1.25 times overall rate for two monthsRaise threshold for affected group pending provider fix; inform provider; review affected casesHead of service
FR-02Complaints or audit findingCorrect notices; reopen affected decisions on requestLegal
FR-05Sample shows flags treated as fraud findingsRetraining; disciplinary process if neededTeam lead
Any serious incidentStaff report, complaint, monitoringStop use if needed; inform provider and authorities as required by the Regulation (Article 26)Senior accountable officer

Governance arrangements: [Example: a steering group (head of service, DPO, legal, equality officer) meets monthly for the first six months, then quarterly, and can suspend use.]

Complaint mechanisms: [Example: applicants can complain online, by phone or in person; complaints mentioning the system are tagged and reviewed within 10 working days; the normal administrative appeal remains available; applicants are informed of their right to an explanation of individual decisions under Article 86 where it applies.]

4. Rights-by-rights analysis

Right (EU Charter)Relevant?Linked risksComment
Human dignity[Yes / No]FR-05
Respect for private and family life[Yes / No]FR-03
Protection of personal data[Yes / No]FR-03See DPIA
Non-discrimination[Yes / No]FR-01
Rights of the child[Yes / No]FR-04
Integration of persons with disabilities[Yes / No]
Social security and social assistance[Yes / No]FR-01
Right to good administration[Yes / No]FR-02
Right to an effective remedy[Yes / No]FR-02
Freedom of expression and information[Yes / No]Usually not relevant for this use

5. Relationship to the DPIA

ItemValue
DPIA reference[DPIA-ID, version, date]
Sections reusedExample: Description of processing (DPIA 2), necessity and proportionality (DPIA 4), data security measures (DPIA 7)
What this FRIA addsExample: Non-discrimination analysis, rights of the child, good administration, complaint handling
DPO opinion[Summary]

6. Notification to the market surveillance authority

ItemValue
Market surveillance authority[Name, Member State]
Template used[AI Office questionnaire template, version / not yet available]
Date submittedYYYY-MM-DD
Reference number[Reference]
Exemption claimed (Article 46(1))[No / Yes, with justification]
Submitted by[@name]
Confirmation received[Yes / No], YYYY-MM-DD

7. Review and update

TriggerElements affectedAction
New system version from provider(d), (e)Review provider information; update risks
Change in process or user group(a), (c)Update and re-notify if results change
Extension of period or frequency(b)Update
Monitoring threshold breached(d), (f)Reassess; consider suspension
Annual reviewAllConfirm or update

8. Conclusion

ItemValue
Overall assessment[Example: Use may proceed; two risks rated medium-high after measures]
ConditionsExample: Group monitoring for FR-01 live before first use; notice wording approved by legal
Residual concerns[Summary]
Decision[@senior-accountable-officer], YYYY-MM-DD

9. Glossary and references

TermMeaning
DeployerA person or body using an AI system under its authority in a professional activity
ProviderThe organisation that develops the AI system and places it on the market under its name
FRIAFundamental rights impact assessment under Article 27 of the AI Act
DPIAData protection impact assessment under Article 35 GDPR
Market surveillance authorityNational authority that supervises AI systems on the market

References: Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744 (consolidated text), Articles 6, 13, 26, 27, 46, 86, 113 and Annex III; Charter of Fundamental Rights of the European Union; Regulation (EU) 2016/679 (GDPR), Article 35; [provider's instructions for use]; [DPIA].

Standard and licence note

Based on Regulation (EU) 2024/1689 (the Artificial Intelligence Act) as amended by Regulation (EU) 2026/1744 (Digital Omnibus on AI), Article 27 on the fundamental rights impact assessment for high-risk AI systems, as published in the Official Journal of the European Union; EU legislative texts are free to reuse. The required elements are summarised in original wording and no text of the Regulation is reproduced. Check the consolidated text on EUR-Lex for the binding wording, any later amendments and the AI Office template; under the amended Article 113 the obligation applies from 2 December 2027 for the Article 6(2) (Annex III) systems it covers. This is a documentation format, not legal advice. Template licence: MIT.

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