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AI Risk Assessment

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A worked example shows this template completed for a fictional mid-size company.

Purpose. A structured assessment of what could go wrong with a specific AI system, how bad it would be, and what you are doing about it. For high-risk systems it is the core evidence that Art. 9 risk management is operating.

When to use it. Before development for high-risk systems, before deployment for all systems, and again on material change. Review live high-risk systems at least annually.

How to use it. Do it with the people who build and use the system, not about them. Assess risk to the people affected first and to the organisation second — that ordering is what the regulation expects, and it also surfaces the risks that later become reputational ones.

Closes assessment gaps

This template addresses Q06, Q09, Q11, Q15, Q24, Q29, Q38 in the readiness assessment.


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The template

System under assessment

Field Value
System ID / name [AI-00X]
Accountable owner [name]
Purpose [what it does and what decisions it drives]
Risk tier [prohibited / high / limited / minimal]
Affects individuals? [yes / no — how]
Assessment date / assessor [date] / [name]

1. Prohibited practice screen

Answer first. Any "yes" stops the assessment.

  • Deploys subliminal, manipulative, or exploitative techniques
  • Exploits vulnerability by age, disability, or social/economic situation
  • Performs social scoring leading to unjustified detrimental treatment
  • Predicts criminal offending based solely on profiling or personality
  • Builds facial recognition databases by untargeted scraping
  • Infers emotion in the workplace or in education
  • Performs biometric categorisation to infer protected characteristics
  • Performs real-time remote biometric identification in public spaces

Any box ticked → do not proceed. Escalate immediately.

2. Harms assessment

Assess harm to people first.

Harm type Could it occur? Who is affected? Severity Likelihood Rating
Discrimination / unfair outcome
Loss of opportunity (job, credit, service)
Financial loss
Physical or psychological harm
Privacy intrusion
Loss of autonomy or ability to contest
Misinformation
Exclusion of a group

Then to the organisation: regulatory, financial, reputational, operational.

Ask who is worst affected, not who is average

Aggregate accuracy hides concentrated harm. A system that is 95% accurate overall can be systematically wrong about one group — and that group is who will be harmed, and who will complain.

3. Technical risk

Area Question Assessment Mitigation
Data quality Is training data relevant, representative, current?
Bias Have you tested performance across subgroups?
Accuracy Does it meet the declared threshold? Where does it fail?
Robustness How does it behave on edge cases and adversarial input?
Drift How would you detect degradation?
Explainability Can you explain a decision to the person affected?
Security Injection, poisoning, extraction, leakage through output?
Dependencies What happens if the vendor or model changes?

4. Human oversight

Question Answer
Who reviews the output? [named role]
What information do they see?
Can they realistically override? How?
How long do they have per decision?
How would we know if they were rubber-stamping?
What training have they had?

The rubber-stamp test

If a reviewer handles hundreds of decisions an hour, or overrides almost never, oversight is nominal. Measure override rates — a rate near zero is a warning sign, not a success metric.

5. Transparency

  • People are told they are interacting with, or subject to, AI
  • AI-generated content is marked where required
  • Affected people can obtain an explanation
  • There is a route to contest a decision, and someone staffs it

6. Residual risk and decision

Residual rating Justification Accepted by Authority Date
[low/med/high/critical] [name] Per Decision Rights & Escalation [date]

Decision: Proceed · Proceed with conditions · Do not proceed

Conditions: [list, with owners and dates]

7. Review

Trigger Action
Material change of purpose or data Full reassessment
Incident involving this system Targeted reassessment
Annually (high-risk) Full review — see Annually, and on any material change of purpose, data, or modelUnless: Every six months where the model is retrained frequently or the vendor ships model changes without notice.
Vendor model change Targeted reassessment

Adaptation notes

  • Small organisations: Sections 1, 2, and 4 are the irreducible core: is it allowed, who could it hurt, and who is watching. That fits on two pages.
  • Regulated financial services: Align with model risk management: add model validation findings, and treat this as a complement to, not a replacement for, independent validation.
  • Where a DPIA is also required: Run them together and cross-reference. Section 2 harms feed the DPIA's risks-to-individuals directly — see Processing & DPIA Log.
  • Research and experimentation: Apply a shortened version at experiment stage, and the full assessment before anything touches real users or real decisions.

Not legal advice

These templates are a head start, not a substitute for professional judgement. Adapt them to your jurisdiction, sector, and risk appetite, and have qualified counsel review anything material before you rely on it.