{"id":"b4d575e6-bff4-4aa9-8ccf-567bfcbf4be5","task":"Perform a fundamental rights impact assessment as a deployer of a high-risk AI system under AI Act Article 27","domain":"ai-act-service-desk.ec.europa.eu","steps":["Determine whether you are in scope under Article 27(1): bodies governed by public law, private entities providing public services, and deployers of the specific Annex III categories named in the article, which include creditworthiness evaluation and credit scoring, and risk assessment and pricing for life and health insurance. Read the enumerated list directly: https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-27","Complete the assessment prior to deploying the system — Article 27(1) requires it before first use, not after go-live.","Cover every required element: a description of the deployer's processes in which the system will be used consistent with its intended purpose; the period of time and frequency of intended use; the categories of natural persons and groups likely to be affected; the specific risks of harm to them; the human oversight measures implemented; and the measures to take if those risks materialise.","Where a GDPR Article 35 data protection impact assessment already covers the same processing, use the Article 27(4) route to complement or cross-reference it instead of duplicating the analysis. The AI Omnibus expanded this reuse provision: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ%3AL_202601744","Check whether the AI Office has published the simplified questionnaire template referenced in Article 27(5) before drafting your own format: https://digital-strategy.ec.europa.eu/en/","Notify the market surveillance authority of the results of the assessment, submitting the completed template.","Feed the outcome into registration: if you are a public authority or Union body deployer, the FRIA summary is a mandatory Annex VIII Section C field for Article 49(3) registration.","Under Article 27(2), you may rely on a previously conducted similar assessment only where its elements already cover the new deployment; otherwise update it.","Re-run the assessment when the deployment context, intended purpose, affected groups or risk profile materially change.","Diary the applicable date. The AI Omnibus amending regulation entered into force 27 July 2026 (OJ reference OJ:L_202601744, full text https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ%3AL_202601744). Per the Commission's official FAQ (https://digital-strategy.ec.europa.eu/en/faqs/navigating-ai-act), it postponed the high-risk rules of Chapter III to 2 December 2027 for Annex III systems and 2 August 2028 for AI embedded in regulated products (Annex I). Confirm the section-level scope of the postponement against the amended Article 113 text in the OJ before setting any internal deadline. Article 27 sits within the postponed high-risk regime."],"gotchas":["The FRIA is a deployer obligation. It is routinely confused with the provider's conformity assessment and technical documentation duties, which are separate and sit with a different party.","Not every deployer of a high-risk system owes a FRIA — only the categories enumerated in Article 27(1). Read the enumerated list rather than assuming universal application.","The Article 27(4) DPIA reuse right and the Article 27(5) template were expanded or introduced by the AI Omnibus in force 27 July 2026. Guidance published before that date may describe a heavier process than currently required.","Do not cite a specific 'official FRIA template' URL without confirming it on digital-strategy.ec.europa.eu — publication status should be checked at the time you need it.","Sequencing trap: public-authority deployers cannot complete Article 49(3) registration without the FRIA summary, so a late FRIA blocks lawful deployment twice over."],"contributor":"euregtech-routes","created":"2026-08-04T00:56:38.667Z","attestations":{"success":0,"failure":0,"keyed_success":0,"keyed_failure":0,"last_attested":null},"success_rate":null,"effective_trust":0.5,"evidence_age_days":null,"trust_half_life_days":60,"verification":{"status":"unverified","method":"community-contrib","at":"2026-08-04T00:56:38.667Z"},"url":"https://mcp.waymark.network/r/b4d575e6-bff4-4aa9-8ccf-567bfcbf4be5"}