# Fundamental Rights Impact Assessment (FRIA) Template

**Version:** 1.0
**Last Updated:** 2026-06-01
**Legal basis:** EU AI Act (Regulation (EU) 2024/1689), Article 27
**Source:** KLA Digital (kla.digital/tools/fria-generator)

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## About This Template

A Fundamental Rights Impact Assessment (FRIA) is the assessment that **deployers** of certain high-risk AI systems must complete under **Article 27** of the EU AI Act before putting the system into use. It examines how the system could affect people's fundamental rights — non-discrimination, privacy, human dignity, access to justice, and more — and documents the safeguards in place.

This template reproduces the six mandatory elements of **Article 27(1)(a)–(f)**. It is provided for information only and is **not legal advice**; confirm your obligations with qualified counsel.

### Timing (status as of June 2026)

- The Article 27 FRIA obligation was originally set to apply from **2 August 2026** (stand-alone Annex III high-risk systems).
- The EU's **Digital Omnibus**, provisionally agreed ~7 May 2026, would defer that date to **2 December 2027** (and to **2 August 2028** for high-risk AI embedded in regulated products).
- **That deferral is not yet law.** Until it is adopted and published in the Official Journal, **2 August 2026 remains the binding date**. Keep preparing on that basis and re-check the status before relying on any deadline.

### Who must complete a FRIA

A FRIA is required of deployers that are:
- **public bodies** or private entities **providing public services** (education, healthcare, social services, housing, justice), using high-risk AI listed in Annex III; and
- **any deployer** using AI for **creditworthiness / credit scoring** (except fraud detection) or **risk assessment and pricing in life and health insurance**.

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## How to Use This Template

1. Read the guidance under each section.
2. Replace the bracketed placeholders with your own information.
3. Complete the **risk register** (Section 4) — one row per fundamental right at risk.
4. Have the completed FRIA reviewed and approved internally, then notify the market surveillance authority of the results (Article 27(3)).

If a section does not apply, say so explicitly rather than leaving it blank. Re-run the FRIA whenever the system, its context, the affected population, or the known risks change materially.

> **Tip:** the interactive [FRIA generator](https://kla.digital/tools/fria-generator) fills this structure in your browser and exports a draft in Markdown or JSON.

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## Section 1 — System Description & Intended Purpose
*Article 27(1)(a)*

Describe the deployer's processes in which the high-risk AI system will be used, in line with the intended purpose defined by the provider.

- **AI system name and version:** [e.g. CreditScore AI v3.2]
- **Provider and contact:** [provider legal name + compliance contact]
- **Intended purpose (as defined by the provider):** [...]
- **Deployer process where the system is used:** [...]
- **Operational context and environment:** [...]

> *Example:* Automated assessment of consumer creditworthiness for personal-loan applications, used in the retail-lending origination workflow to recommend approve / refer / decline outcomes to a loan officer who reviews every output.

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## Section 2 — Duration & Frequency of Use
*Article 27(1)(b)*

Describe the period of time within which, and the frequency with which, the system is intended to be used.

- **Planned deployment start date:** [YYYY-MM-DD]
- **Expected duration:** [indefinite / fixed term / pilot]
- **Frequency of use:** [continuous / periodic / event-triggered]
- **Volume of decisions:** [e.g. decisions per day / month]
- **Geographic scope:** [...]

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## Section 3 — Categories of Affected Persons
*Article 27(1)(c)*

Identify the categories of natural persons and groups likely to be affected in the specific context.

- **Persons subject to AI-driven decisions:** [...]
- **Third parties indirectly affected:** [...]
- **Vulnerable groups requiring special attention:** [children, elderly, persons with disabilities, minorities, non-native speakers, low digital literacy, ...]

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## Section 4 — Specific Risks to Fundamental Rights
*Article 27(1)(d)*

Identify the specific risks of harm to the persons above, using the information the provider must supply under Article 13. Record each risk in the register.

- **Fundamental rights potentially at risk:** [non-discrimination (Art 21), data protection (Art 8), dignity, access to essential services, ...]
- **Provider information relied on (Article 13):** [Annex IV documentation, instructions for use, bias-testing results, ...]

### Risk-scoring matrix (likelihood × severity)

| Likelihood ↓ / Severity → | Negligible | Minor | Moderate | Major | Catastrophic |
| --- | --- | --- | --- | --- | --- |
| **Rare** | Low | Low | Low | Medium | Medium |
| **Unlikely** | Low | Low | Medium | Medium | High |
| **Possible** | Low | Medium | Medium | High | High |
| **Likely** | Medium | Medium | High | High | Critical |
| **Almost certain** | Medium | High | High | Critical | Critical |

### Risk register

| Fundamental right | Harm scenario | Likelihood | Severity | Risk level | Mitigation | Residual risk |
| --- | --- | --- | --- | --- | --- | --- |
| [right] | [harm] | [rare…almost certain] | [negligible…catastrophic] | [Low/Medium/High/Critical] | [measures] | [Low/Medium/High/Critical] |

> *Worked example (credit scoring):*
>
> | Fundamental right | Harm scenario | Likelihood | Severity | Risk | Mitigation | Residual |
> | --- | --- | --- | --- | --- | --- | --- |
> | Non-discrimination (Art 21) | Historical bias and proxy variables (e.g. postcode) produce disparate decline rates. | Possible | Major | High | Quarterly disparate-impact testing; remove proxy features; human review of declines for underrepresented groups. | Medium |
> | Access to essential services / property | An erroneous low score wrongly denies credit. | Unlikely | Major | Medium | Manual-assessment pathway; human override; clear adverse-action explanation. | Low |
> | Protection of personal data (Art 8) | Excessive or inaccurate data degrades fairness and accuracy. | Possible | Moderate | Medium | Data-minimisation review; DPIA integration; data-quality controls (Art 10). | Low |

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## Section 5 — Human Oversight Measures
*Article 27(1)(e)*

Describe how human oversight is implemented, in accordance with the instructions for use.

- **Designated oversight roles:** [...]
- **Intervention capabilities:** [override, request information, escalate, stop control, ...]
- **Qualifications and training:** [automation-bias training, refresh cadence, ...]

---

## Section 6 — Measures if Risks Materialise: Governance & Complaints
*Article 27(1)(f)*

Describe the measures to be taken if the identified risks materialise, including internal governance and complaint mechanisms.

- **Technical measures:** [bias audits, accuracy thresholds, logging, ...]
- **Organizational measures:** [governance committee, policies, review cycles, ...]
- **Complaint and redress mechanisms:** [right to human review, complaint channel, remediation SLA, fallback, ...]
- **Notification to the market surveillance authority (Art 27(3)):** [notify the authority of the FRIA results, submitting the Article 27(5) template once available]

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## Review & Approval

- **Prepared by:** [name / role] — [date]
- **Reviewed by (legal/compliance):** [name / role] — [date]
- **Approved by:** [name / role] — [date]
- **Next review due:** [date or trigger conditions]

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*This template is for general information only and does not constitute legal advice. Confirm your obligations under Article 27 of the EU AI Act with qualified counsel, and re-check the regulatory status (including the Digital Omnibus) before relying on any deadline.*
*Generated by KLA Digital — kla.digital/tools/fria-generator*
