FRIA in the AI Act

Why it matters for NETEVO

Mantelero (2024) is the legal-scholarship companion to ISO/IEC 42005:2025 in NETEVO's substrate. Where the standard operationalises Article 27 of the EU AI Act in management-system form, Mantelero specifies the underlying legal obligation, supplying peer-reviewed authority for the same workflow.

Pairing standards-side and legal-side authority. Citing the two together gives NETEVO's impact-assessment workflow a defensible footing on both axes — the standard supplies the conformity scaffolding, the article supplies the legal scaffolding. This is the shape required to defend the one template, five regulatory hooks finding that underwrites the AI System Impact Assessment as a single artefact satisfying ISO/IEC 42001 conformity, Article 27 Fundamental Rights Impact Assessment, the Australian Privacy Act PIA obligation, the OAIC AI ethics framework, and the NSW AI Assessment Framework concurrently. Without the Mantelero anchor, the FRIA limb of that argument rests on the Regulation text alone; with it, the limb is supported by leading European legal scholarship.

A drafting template that maps to standards-side annex content. Mantelero's article-by-article reading derives the key elements practitioners need to build a model FRIA template — roots, scope, obligations, and structural components. These elements map cleanly onto the example template carried in ISO/IEC 42005 Annex E. Drafters building the AI System Impact Assessment workflow can cross-reference both: Mantelero supplies the legal scaffolding, the standard supplies the operational scaffolding.

Forward use. The FRIA anchor is load-bearing for the forthcoming AI-Washing Audit whitepaper and the next revision of the AI Governance in ANZ working title — Article 27 is the most likely shape the AU mandatory-guardrail impact-assessment requirement takes in practice, making the European treatment a working benchmark for AU listed and pre-listing leaders.