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FRIA · EU AI Act Art. 27

FRIA: the AI Act obligation that should already be in place

From 2 February 2026, deploying high-risk AI in the EU requires a Fundamental Rights Impact Assessment. If yours lives in a Word document in a shared folder, it does not exist as far as the auditor is concerned.

2026-02-02 enforceable from
4 eyes approver ≠ drafter
Redress mandatory mechanism

EU legal obligation

What a FRIA is and why it matters

FRIA

The FRIA (Fundamental Rights Impact Assessment) is the assessment of the impact on fundamental rights required by Article 27 of the EU AI Act from deployers of high-risk AI systems in the European Union. It has been mandatory since 2 February 2026 — it is not a recommendation, and its absence is an audit finding.

A FRIA assesses the affected groups, the rights at stake (with probability and severity), the mitigation measures, human oversight and the redress mechanism. It is not the same as a GDPR DPIA, although the two can reference each other.

What Art. 27 requires

Linedat models the FRIA as a versioned dossier linked to the AI system, with separation of duties and an automatic finding when it is missing.

Linked to the AI system

The FRIA is tied to an inventoried high-risk AI system with its risk class — there are no orphan FRIAs.

Impact on fundamental rights

Affected groups (including vulnerable populations) and rights at stake with likelihood × severity.

Mitigation, oversight and redress

Mitigation measures, human oversight and a mandatory redress mechanism.

Approval with separation of duties

The person who drafts the FRIA cannot approve it; approval requires four eyes.

How Linedat covers it

Linedat models the FRIA as a versioned dossier linked to the AI system, with separation of duties and an automatic finding when it is missing.

FAQ

Respuestas sobre implementación y capacidades

No. The DPIA (Art. 35 GDPR) assesses the impact on personal data protection; the FRIA (Art. 27 AI Act) assesses the impact on fundamental rights of an AI system. In Linedat a FRIA can cite a DPIA as evidence, but they are independent documents.

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