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• Create Date August 24, 2025
• Last Updated August 24, 2025

AI EU AI Act Risk Assessment Checklist

Ensure compliance with Articles 5, 6, and Annex III using a structured EU AI Act Risk Assessment framework.

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The EU AI Act Risk Assessment process requires organizations to classify AI systems, evaluate risks, and prepare technical documentation before deployment. This checklist provides a comprehensive, audit-ready framework to ensure that every stage — from system identification to post-market monitoring — is documented, compliant, and ready for conformity assessment.

Key Benefits:

• ✅ Comprehensive Coverage: Includes classification, risk management, data governance, oversight, and FRIA.

• ✅ EU AI Act Compliance: Mapped to Articles 5, 6, Annex III, and systemic risk provisions.

• ✅ Audit-Ready: Supports conformity documentation, QMS integration, and CE marking requirements.

• ✅ Lifecycle Alignment: Covers design, pre-market, deployment, and post-market monitoring.

• ✅ Human Oversight: Includes specific obligations for biometric and high-risk AI systems.

Who Uses This?
Compliance officers, CAIOs, risk managers, and governance committees conducting EU AI Act Risk Assessments for high-risk and general-purpose AI systems.

Why This Matters

The EU AI Act mandates a structured EU AI Act Risk Assessment for all AI systems, with enhanced requirements for high-risk categories such as biometrics, education, employment, and essential services. Organizations that fail to perform proper classification and oversight face fines and loss of market access. This checklist helps organizations conduct an EU AI Act Risk Assessment systematically, reducing compliance risk and ensuring audit readiness.

Framework Alignment

The checklist aligns with:

• EU AI Act — Articles 5 & 6, Annex III high-risk categories, FRIA requirements.

• NIST AI RMF — Lifecycle risk management integration.

• ISO/IEC 42001 & 23894 — AI governance and risk management standards.

• GDPR & Fundamental Rights — Human oversight, privacy, and fairness integration.

• OECD AI Principles — Transparency, accountability, and human-centric AI.

Key Features

• Initial Classification: System ID, classification screening, Annex III category mapping.

• High-Risk Derogation: Article 6(3) exemptions and justifications.

• Risk Management System: Risk identification, mitigation, testing, and vulnerable group impact analysis.

• Data Governance: Data quality, bias detection, and transparency requirements.

• Human Oversight: Oversight design, biometric system requirements, decision authority matrix.

• Fundamental Rights Impact Assessment (FRIA): Applicability and required components.

• Technical Compliance: Performance standards, transparency obligations, logging, traceability.

• Documentation Package: Technical documentation, QMS integration, conformity declaration.

• Post-Market Monitoring: Continuous monitoring, incident reporting, and systemic risk assessments.

• General-Purpose AI Models: Systemic risk obligations for GPAI under Article 52.

Comparison Table

FAQ Section 

Q1: What is the EU AI Act Risk Assessment Checklist?
A: It is a structured tool for performing an EU AI Act Risk Assessment, covering classification, risk management, data governance, and conformity documentation.

Q2: Which articles and annexes does it support?
A: It maps to Articles 5, 6, Annex III, FRIA requirements, and systemic risk provisions for general-purpose AI.

Q3: Does it include high-risk system checks?
A: Yes. The checklist includes Annex III categories (biometrics, education, employment, essential services, law enforcement, migration, and justice).

Q4: Is it suitable for SMEs as well as enterprises?
A: Yes. SMEs can adapt the core compliance requirements, while larger organizations can implement the full conformity documentation package.

Q5: Does it include FRIA obligations?
A: Yes. The checklist includes Fundamental Rights Impact Assessment (FRIA) applicability, components, and reporting steps.

Q6: What format is best for using this template?
A: Documents are best viewed and used via Microsoft Word or Excel. Formatting may not fully display in Google Docs or other editors.

Ideal For

• EU AI Act Compliance Teams

• Chief AI Officers (CAIOs)

• Governance & Risk Committees

• Data Governance & Legal Teams

• Audit & Conformity Assessment Teams

• Vendors supplying high-risk AI systems