Fundamental Rights Impact Assessment

Meet your Article 27 obligations before you deploy

Required under Article 27 before you deploy a high-risk AI system. Not optional.

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EU AI Act High-Risk Deployer Checklist

If your organisation uses AI systems in your business, the EU AI Act classifies you as a deployer and specific obligations apply to you. This checklist maps each of those obligations to the Article that requires it, so you know exactly what your governance needs to include before 2 August 2026.

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The Problem

Why this matters

A Fundamental Rights Impact Assessment is a structured governance document required under Article 27 of the EU AI Act before deploying a high-risk AI system in specific contexts. Those contexts include employment and worker management, essential services, education and vocational training, law enforcement, and the administration of justice.

A FRIA is not optional for deployers in these categories. It maps the deployment context against the fundamental rights at stake, documents the anticipated impact on specific groups, records the mitigations put in place, and establishes the residual risk accepted by the organisation. It must exist before deployment, and it must be available to competent authorities on request.

Many organisations in regulated sectors are using AI systems that fall under the EU AI Act's high-risk classification without knowing it. A FRIA is a legal obligation for deployers of those systems, not an optional exercise.

What Is Included

A structured FRIA engagement covering scoping, rights assessment, impact analysis, mitigation design, and documentation:

  • Deployment context analysis: what the system does, who is affected, and which fundamental rights categories are relevant
  • Affected group identification: which individuals or categories of people are subject to the system's outputs or decisions
  • Impact assessment: probability and severity of potential impact on each fundamental right identified
  • Mitigation design: controls that reduce identified risks to an acceptable residual level
  • Residual risk documentation: what risk remains after mitigations and who in the organisation accepts it
  • Final FRIA document, version-controlled and suitable for regulatory submission

Legal review of the completed FRIA by qualified counsel is recommended before formal regulatory submission or use as a primary compliance defence document.

Deliverables

What you receive

  • Deployment context report: system description, affected groups, fundamental rights categories in scope
  • Impact assessment matrix: each right assessed for probability and severity of impact
  • Mitigation register: controls designed to address each identified impact
  • Residual risk register: risks remaining after mitigation, with named accountable owner
  • Final FRIA document: complete, dated, version-controlled, and ready for regulatory review

Enterprise Ireland

If your organisation is Enterprise Ireland-supported, you may be able to recover up to 80% of project costs via the Digital Discovery Grant. Book a discovery call and we will confirm your eligibility as part of the conversation.

Find out if you qualify

Insights

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Scope and boundaries

What we are

We have received comprehensive training and are knowledgeable across the full scope of EU AI Act obligations: risk classification, provider and deployer requirements, governance architecture, post-market monitoring, and fundamental rights assessments. Clear Gate Systems applies this knowledge to design and implement technical governance architecture for clients.

What we are not

Clear Gate Systems does not provide legal advice, legal interpretation of specific obligations, or regulatory representation. Where your organisation requires a formal legal opinion, on the classification of a specific system, on contractual obligations with an AI vendor, or on regulatory exposure, a qualified solicitor or barrister must be engaged. Our role is to build the technical governance infrastructure that qualified legal counsel can stand behind.

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