Proposing PaFRIA: A Participatory Fundamental Rights Impact Assessment Aligned with the EU AI Act

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Authors: Chiara Ullstein, Michel Hohendanner, Orestis Papakyriakopoulos, Jens Großklags
Cited by: 1
References: 57

Abstract

Under the EU AI Act, assessing the impact of AI systems on fundamental rights (FRIA) is a core obligation for certain high-risk AI system deployers (Article 27). To support compliance, the AI Office is tasked with developing a FRIA template. However, no such template currently exists. AI Act Recital 96 explains the FRIA obligations and suggests stakeholder involvement in FRIA. To address the gap in guidance and support stakeholder involvement as suggested in Recital 96, we propose PaFRIA, a participatory FRIA in line with the AI Act. It assists AI deployers in complying with the AI Act's FRIA obligations, and facilitates stakeholder involvement in the assessment process. We iteratively refined PaFRIA through participatory engagement with deployers, affected end-users, and experts. The iterations revealed six clusters of tensions, which we translated into basic principles for designing a participatory AI Act-aligned FRIA. We present the resulting PaFRIA and discuss its implementation.

Fields of Study & Subjects

Law AI and Intellectual Property Human Rights and Development Environmental law and policy

Publication details

Journal / source
Proceedings of the 2026 ACM Conference on Fairness, Accountability, and Transparency
Publisher
ACM
Pages
3779–3803
Publication date
25 June 2026