Data protection officer
“We are about to deploy a high-risk AI system. Does the AI Act also send us to a GDPR data protection impact assessment?”
Yes, where one applies.
The AI Act tells deployers of high-risk AI systems to use the information the provider gives them under Article 13. They use it to carry out their data protection impact assessment under Article 35 GDPR 1.
The GDPR side sets the test. When processing is likely to result in a high risk to the rights and freedoms of natural persons, the controller must carry out the assessment first 2.
I checked the quoted words against the official AI Act text and they match. The text tells you what applies; whether your processing meets the high-risk test is a call for your team.
4 calls: one search across the acts, two passage reads, one citation check · 542 ms
Marginal notes
Note 1: EU AI Act, Article 26(9)
Where applicable, deployers of high-risk AI systems shall use the information provided under Article 13 of …
Official text from EUR-Lex, CELEX 32024R1689, as held on 2 Sep 2026. Open on EUR-Lex
Note 2: GDPR, Article 35(1)
Where a type of processing in particular using new technologies, and taking into account the nature, scope …
Official text from EUR-Lex, CELEX 32016R0679, as held on 2 Sep 2026. Open on EUR-Lex
Ask it yourself
We are about to deploy a high-risk AI system. Does the AI Act also send us to a GDPR data protection impact assessment?