High risk · Annex III(7)

AI in Migration & Border Control: High-Risk (EU AI Act Annex III)

AI at the border can decide who enters a country and who is turned away. Annex III point 7 makes these uses high risk given their impact on fundamental rights.

What Annex III(7) covers

  • Polygraphs and similar tools
  • Assessing security, irregular-migration and health risks
  • Examining applications for asylum, visa and residence permits
  • Detecting and recognising persons (except document verification)

Who’s affected

Immigration and border authorities and the vendors supplying risk-assessment or biometric-matching AI for migration.

Why it’s high risk

High risk under Annex III(7). Public bodies deploying these systems must also complete a Fundamental Rights Impact Assessment (Art. 27) before first use.

Obligations to prepare for

Risk management system (Art. 9)
Data governance & bias checks (Art. 10)
Technical documentation — Annex IV (Art. 11)
Record-keeping / logging (Art. 12)
Transparency & instructions (Art. 13)
Human oversight (Art. 14)
Accuracy, robustness & cybersecurity (Art. 15)
Fundamental Rights Impact Assessment (Art. 27)

FAQ

Does the EU AI Act cover asylum decision AI?

Yes — AI assisting the examination of asylum, visa and residence applications is high-risk under Annex III(7), and public-body deployers must complete a Fundamental Rights Impact Assessment.

Being high-risk sets the obligations; your role decides who owns them. See provider vs deployer duties.

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