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FRIA Scope & EU Charter Rights

Article 27 requires certain categories of deployer to conduct a Fundamental Rights Impact Assessment (FRIA) before putting the system into service. The obligation applies to deployers that are bodies governed by public law, private entities providing public services, and deployers using high-risk systems for creditworthiness evaluation or risk assessment and pricing in life and health insurance (as specified in Article 27(1), cross-referencing Article 26(10)). Other deployers are not subject to the Article 27 FRIA obligation, although conducting a voluntary FRIA is strongly recommended as a governance best practice. The assessment must cover all fundamental rights recognised under the EU Charter that could plausibly be affected by the system’s operation. The FRIA must not be treated as a template exercise; the AI System Assessor tailors it to the specific system, deployment context, and affected populations.

For a recruitment screening system, relevant Charter rights include non-discrimination (Charter Article 21), freedom to choose an occupation (Charter Article 15), protection of personal data (Charter Article 8), the right to an effective remedy (Charter Article 47), and the right to good administration (Charter Article 41). For a credit scoring system, the right to property (Charter Article 17) and the prohibition of discrimination in access to services become relevant. Each system requires a bespoke rights analysis.

The FRA’s 2023 methodology template provides the most applicable framework, structuring the assessment around six steps: describe the AI system and context; identify rights at stake; assess risks to those rights; evaluate existing safeguards; assess proportionality and necessity; and identify additional mitigation measures. Each step produces documentation feeding into AISDP Module 11.

Key outputs

• Bespoke EU Charter rights analysis per system and deployment context
• Six-step FRA methodology application
• Documentation per step feeding into Module 11
• Module 6 and Module 11 AISDP evidence