Article 6(3) Not-High-Risk Assessment: [AI system] [version]
Documented assessment by a provider that an AI system falling within
an Annex III area is not high-risk under Article 6(3) of the EU
Artificial Intelligence Act (Regulation (EU) 2024/1689 as amended by
Regulation (EU) 2026/1744, the Digital Omnibus on AI), with the
Article 6(4) documentation duty and the Article 49(2) registration
in the EU database. It records the Annex III area, the profiling
check, the condition relied on, the significant-risk reasoning, the
evidence, and the triggers for reassessment. Replace every
[bracketed] value and every row marked Example. Under the amended
Article 113, Chapter III Sections 1 to 3 apply from 2 December 2027
for Annex III systems; the Commission published draft classification
guidelines on 19 May 2026. Check the consolidated text and the final
guidelines. This is a documentation format, not legal advice: check
the current official text and a qualified professional.
Document control
| Field | Value |
|---|
| Document ID | [EXA-001] |
| Provider | [Legal name, address] |
| AI system and version | [Name, version] |
| Intended purpose (as stated in documentation) | [One sentence] |
| AI system inventory ID | [AIS-ID] |
| Guidance relied on | [Commission guidelines under Article 6(5), version and date] |
| Version | [0.1] |
| Status | [Draft / Approved / Registered / Superseded] |
| Owner | [@product-owner] |
| Assessors | [@regulatory-lead], [@legal], [@ml-lead], [@fundamental-rights-expert] |
| Approved before placing on market | [Yes], YYYY-MM-DD |
| EU database registration reference | [Reference] |
| Last updated | YYYY-MM-DD |
Approvals
| Role | Name | Decision | Date |
|---|
| Regulatory lead | [@name] | [Approve / Reject: treat as high-risk] | YYYY-MM-DD |
| Legal counsel | [@name] | [Decision] | YYYY-MM-DD |
| Accountable executive | [@name] | [Decision] | YYYY-MM-DD |
Revision history
| Version | Date | Author | Change summary |
|---|
| 0.1 | YYYY-MM-DD | [@name] | First draft |
| 1.0 | YYYY-MM-DD | [@name] | Example: Approved; registered under Article 49(2) |
| 1.1 | YYYY-MM-DD | [@name] | Example: Reassessed after proposed rank-based slot feature (section 7) |
Contents
1. System description
| Item | Value |
|---|
| Function | Example: CRV Schedule Assist by Tarnwick Analytics proposes interview time slots for candidates a recruiter has already chosen to invite |
| Inputs | Example: Recruiter and interviewer calendars, candidate-stated availability, room bookings |
| Outputs | Example: Three proposed slots per candidate, sent after recruiter confirmation |
| Who uses the output | Example: Recruiters and candidates |
| Decisions it feeds | Example: None about suitability; only the time of an interview already decided by a human |
| Data not used | Example: CV content, application answers, scores from CRV Shortlist or any other ranking |
2. Annex III area
| Question | Answer |
|---|
| Annex III point | Example: Point 4(a), AI systems intended for recruitment or selection of natural persons |
| Reason it falls within the area | Example: The system is part of the recruitment process and is marketed to recruiters |
| Annex I product? | [No] |
| Same provider's other systems in the process | Example: CRV Shortlist 2.4, which is treated as high-risk and documented separately |
3. Profiling check
| Question | Answer | Reasoning and evidence |
|---|
| Does the system process personal data? | [Yes / No] | Example: Yes, names, contact details and availability |
| Does it evaluate personal aspects of a person? | [Yes / No] | Example: No. It matches free time; it does not assess the candidate |
| Does it analyse or predict behaviour, reliability, preferences or performance? | [Yes / No] | Example: No. Slot order is by earliest date, not by predicted attendance |
| Could configuration options turn it into profiling? | [Yes / No] | Example: No; no option to weight candidates. Section 7 lists features that would change this |
| Profiling result | [Profiling / No profiling] | If profiling: stop, the system is high-risk |
4. Condition relied on (Article 6(3)(a) to (d))
| Ref | Condition (summarised) | Relied on? | Reasoning |
|---|
| (a) | The system performs a narrow procedural task | [Yes / No] | Example: Yes. It converts a decision already taken (invite) into a calendar slot; it has no effect on whether the person is invited or selected |
| (b) | The system improves the result of a human activity already completed | [Yes / No] | Example: No |
| (c) | The system detects decision patterns or deviations from earlier patterns, is not meant to replace or influence the completed human assessment, and is subject to proper human review | [Yes / No] | Example: No |
| (d) | The system performs a preparatory task to an assessment relevant to an Annex III use case | [Yes / No] | Example: No. Scheduling follows the assessment, it does not prepare it |
| ID | Evidence | Location |
|---|
| EV-01 (Example) | Functional specification showing inputs and outputs | Spec SA-SPEC-3 |
| EV-02 (Example) | Data flow diagram showing no link to ranking scores | Architecture record AR-11 |
| EV-03 (Example) | Test showing slot proposals do not vary with application content | Test report TR-45 |
5. Significant risk and material influence
| ID | Possible harm | Rights concerned | Assessment | Mitigation |
|---|
| H-01 (Example) | Candidates with caring duties get fewer convenient slots | Non-discrimination | Low: candidates state their own availability and may request other times | "None of these times work" option always shown |
| H-02 (Example) | Missed interview due to scheduling error affects outcome | Non-discrimination, good administration | Low: the error affects timing, recruiter can reschedule | Rescheduling link in every message |
| H-03 (Example) | Accessibility needs not captured | Integration of persons with disabilities | Low with mitigation | Free-text adjustment request routed to recruiter |
Material influence conclusion: [Example: The system does not
materially influence whether a candidate is selected. It acts only
after the human invitation decision and does not use any information
about the candidate's suitability.]
6. Registration and documentation duties
| Duty | Status | Evidence |
|---|
| Assessment documented before placing on the market or putting into service (Art. 6(4)) | [Done], YYYY-MM-DD | This document, version [x] |
| Provider and system registered in the EU database (Art. 49(2)) | [Done / Pending], YYYY-MM-DD | [Reference] |
| Annex VIII Section B information submitted | [Done] | Provider and contact details, trade name and reference, intended purpose, the Article 6(3) condition relied on, status |
| Documentation provided to national competent authority on request (Art. 6(4)) | [Not requested / Provided YYYY-MM-DD] | [Reference] |
| Other duties still apply | [Checked] | Article 50 transparency where relevant, Article 4 literacy measures, GDPR |
7. Reassessment triggers
| Trigger | Why it matters | Action |
|---|
| Example: Proposed feature to offer earlier slots to higher-ranked candidates | Uses suitability scores: influences outcome and may be profiling | New assessment; likely high-risk |
| Example: Predicting no-show likelihood to overbook slots | Predicts behaviour: profiling | Treat as high-risk |
| New intended purpose or customer segment | May change Annex III area | Reassess |
| Final Commission guidelines published or changed | Interpretation may narrow the condition | Reassess within [30 days] |
| Market surveillance authority query (Art. 80) | Possible reclassification | Escalate to legal |
| Scheduled review | Drift between documentation and product | Every [12 months] |
8. Conclusion
| Item | Value |
|---|
| Outcome | [Not high-risk under Article 6(3) / High-risk] |
| Condition relied on | Example: Article 6(3)(a), narrow procedural task |
| Profiling | Example: None |
| Conditions attached | Example: No link to ranking scores; features in section 7 need a new assessment |
| Decision by | [@accountable-executive], YYYY-MM-DD |
If the outcome is high-risk, continue with ai-data/ai-act-risk-management-system,
ai-data/ai-act-technical-documentation, ai-data/ai-act-instructions-for-use
and ai-data/ai-act-declaration-of-conformity.
9. Glossary and references
| Term | Meaning |
|---|
| Annex III | List of high-risk use case areas in the AI Act, such as employment, education and essential services |
| Profiling | Automated processing of personal data to evaluate personal aspects of a person (GDPR Article 4(4)) |
| Narrow procedural task | A limited task that does not shape the substance of a decision |
| EU database | The database for high-risk AI systems listed in Annex III (Article 71) |
| Market surveillance authority | National authority that checks AI systems on the market |
References (check the current consolidated text and guidelines):
- Regulation (EU) 2024/1689 (AI Act), Articles 6, 49, 71, 80, 113 and Annexes III and VIII: https://eur-lex.europa.eu/eli/reg/2024/1689/oj
- Regulation (EU) 2026/1744 (Digital Omnibus on AI), OJ L 24 July 2026: http://data.europa.eu/eli/reg/2026/1744/oj
- European Commission, draft guidelines on the classification of high-risk AI systems, 19 May 2026 (consultation closed 23 July 2026; no final version adopted as of October 2026): https://digital-strategy.ec.europa.eu/en/library/draft-commission-guidelines-classification-high-risk-ai-systems; check the AI Office pages at https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai for the final version
- Regulation (EU) 2016/679 (GDPR), Article 4(4)
- Related templates: ai-data/ai-use-case-intake, ai-data/ai-system-inventory, ai-data/ai-act-technical-documentation, ai-data/ai-act-instructions-for-use, compliance/ai-regulatory-applicability-register
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
6(3) and (4), Article 49(2), Article 80 and Annex VIII Section B, as
published in the Official Journal of the European Union; EU legislative
texts are free to reuse. The conditions are summarised in original
wording and no text of the Regulation is reproduced. Check the
consolidated text on EUR-Lex and the final Commission guidelines under
Article 6(5) before relying on an assessment. All organisations,
products and figures in examples are fictional. This is a documentation
format, not legal advice. Template licence: MIT.