A team inside the European Commission's Directorate-General for Research and Innovation has published a method for assessing how AI systems affect fundamental rights, according to PPC Land. The note, dated May 2026, was prepared by expert Alessandro Mantelero for the Research Ethics & Integrity Team, with staff member Mihalis Kritikos coordinating. It is written for applicants and ethics reviewers in Horizon Europe and other EU-funded programs, and it states that it "does not constitute official EU guidance." Its reviewer checklist still tells ethics panels to ask for an assessment where a proposal lacks one.
The method rates each right separately on four levels (low, medium, high, very high). Likelihood combines probability and exposure, severity combines gravity and effort, and each pair runs through a 4x4 matrix. The note says variables "should not use numerical values" and that a lower impact on one right cannot offset a higher impact on another. It argues that data protection impact assessments under the GDPR give limited attention to rights other than privacy.
An annex linked to 35 articles of the EU Charter lists AI credit scoring and risk assessment and pricing for life and health insurance under consumer protection. It also flags recommender systems and conversational agents built for general audiences without explainability suited to children. The note says it is aligned with the AI Act, whose Article 27 requires deployers of AI for credit scoring and for life and health insurance pricing to assess rights impact before first use.
PPC Land reports that the note's sources were accessed in 2024 and that it does not reflect the Digital Omnibus on AI, adopted July 8, 2026, which moved Annex III high-risk obligations, including deployer duties, to December 2, 2027. The publication also found several cross-reference errors and no written rule for how the final matrix combines likelihood and severity.