Free Compliance Template

EU AI Act DPIA Template

A Data Protection Impact Assessment is required under Article 26(9) of the EU AI Act for high-risk AI systems. Generate one tailored to your specific AI use case — free, in under a minute.

What is a DPIA under the EU AI Act?

A Data Protection Impact Assessment (DPIA) evaluates how your AI system processes personal data and what risks it poses to individuals' rights. Under the EU AI Act, deployers of high-risk AI systems must conduct a DPIA before putting the system into use.

This isn't just a GDPR DPIA with "AI" added — the EU AI Act requires you to assess risks specific to AI systems: bias, transparency, human oversight, and the quality of training data your provider uses.

A complete EU AI Act DPIA covers:

  • 1. System description — what AI system, provider, model, and purpose
  • 2. Data processing scope — what personal data is processed, data subjects, retention
  • 3. Necessity and proportionality — why AI is needed and whether it's proportionate
  • 4. Risk assessment — bias, discrimination, transparency, accuracy, fundamental rights
  • 5. Mitigation measures — human oversight, monitoring, data quality controls
  • 6. Consultation — DPO sign-off, supervisory authority notification if needed

Who needs an EU AI Act DPIA?

Under Article 26(9), deployers of high-risk AI systems must perform a DPIA. You're a deployer if you use an AI system under your own authority — even if someone else built it.

Common high-risk use cases that require a DPIA:

  • Hiring and recruitment screening (Annex III, 4)
  • Credit scoring and financial assessments (Annex III, 5)
  • Medical diagnosis or triage (Annex III, 5)
  • Education scoring and student assessment (Annex III, 3)
  • Insurance pricing and claims (Annex III, 5)

Not sure if your use case is high-risk? Use the decision tree or scan your AI stack to find out.

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EU AI Act DPIA vs. GDPR DPIA — what's different?

If you already have a GDPR DPIA, you're partway there. But the EU AI Act adds AI-specific requirements that a standard GDPR assessment doesn't cover.

Aspect GDPR DPIA EU AI Act DPIA
FocusPersonal data processingAI system risks + personal data
Bias assessmentNot requiredRequired for high-risk systems
Human oversightNot requiredMust document oversight measures
Training dataNot assessedMust assess data quality & representativeness
Provider docsNot requiredMust reference provider documentation (Art. 13)
Fundamental rightsBroad privacy rightsSpecific AI rights impact (Art. 27)

Already GDPR compliant? The GDPR-to-AI-Act bridge guide shows how to extend your existing work.

What happens without a DPIA?

Deployers who fail to conduct a DPIA for high-risk AI systems face fines of up to €15 million or 3% of worldwide annual turnover — whichever is higher. Beyond fines, operating a high-risk AI system without a proper impact assessment can lead to:

  • Suspension of the AI system by market surveillance authorities
  • Liability claims from individuals affected by the AI system
  • Reputational damage and loss of customer trust

This template provides general guidance based on the EU AI Act text (Regulation 2024/1689). It is not legal advice. Consult a qualified legal professional for formal compliance guidance specific to your situation.