Question 1

Is my system an AI system under Article 3(1) of the EU AI Act?

Accepted Answer

An AI system under Article 3(1) is a machine-based system that operates with some level of autonomy, uses machine learning, logic, or statistics-based approaches, generates outputs such as predictions, recommendations, decisions, or content, and is designed for explicit or implicit objectives.

Question 2

Does my AI system fall under a high-risk use case in Annex III of the EU AI Act?

Accepted Answer

Annex III lists 8 high-risk categories: biometric identification, critical infrastructure, education and vocational training, employment and worker management, essential public and private services, law enforcement, migration and border control, and administration of justice and democratic processes.

Question 3

What type of organisation deployer am I under Article 27?

Accepted Answer

Article 27(1) distinguishes four deployer types: public authorities or bodies, private entities providing public services, entities using AI for credit scoring or life/health insurance assessment, and other private entities. Only the first three are obligated to conduct a FRIA.

Question 4

Which fundamental rights could my AI system impact?

Accepted Answer

The EU Charter of Fundamental Rights covers seven title areas: Human Dignity (Articles 1-5), Freedoms (Articles 6-19), Equality and Non-Discrimination (Articles 20-26), Solidarity (Articles 27-38), Citizens' Rights (Articles 39-46), Justice (Articles 47-50), and General Provisions (Articles 51-54).

Question 5

Do I need to do a FRIA under the EU AI Act?

Accepted Answer

A Fundamental Rights Impact Assessment (FRIA) is mandatory under Article 27 for deployers of high-risk AI systems who are public bodies, private entities providing public services, or entities using AI for creditworthiness or life/health insurance assessment. The deadline is 2 August 2026.

Question 6

Can I reuse my existing DPIA for the FRIA?

Accepted Answer

Yes. Article 27(4) creates a bridge between the FRIA and the GDPR Article 35 DPIA. If you have already conducted a DPIA for the same AI system, you can reuse relevant sections. A comprehensive DPIA may cover 30-40% of FRIA requirements.

Question 7

What is the deadline for conducting a FRIA under the EU AI Act?

Accepted Answer

The FRIA obligation applies from 2 August 2026 — the date when the full provisions on high-risk AI systems become applicable. Deployers already using high-risk AI systems on that date must conduct their FRIA as soon as possible.

Am I required to do a FRIA?

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