Check the conditions of the actual prohibition.
Article 5 addresses specified practices, including harmful manipulation or exploitation, certain social scoring, some biometric uses and workplace or educational emotion recognition, subject to the legal wording and exceptions. The amended text also adds prohibitions concerning certain non-consensual intimate synthetic content and child sexual abuse material from 2 December 2026.
Use the current official provision. Short labels are useful for triage but can omit important conditions, exceptions or applicability dates.
Describe what the system actually does.
Ask which inputs are used, which characteristics are inferred, how the output influences behaviour or treatment and who may be affected. Identify the relevant setting and the proposed purpose. A reassuring product name does not answer these questions.
Keep examples factual and proportionate. A reviewer usually needs a description of the functionality and decision process, not a collection of harmful or sensitive sample material copied into a general governance folder.
Make uncertainty a visible decision point.
Where a credible prohibited-practice concern appears, assign the issue to the appropriate legal and operational reviewers. Record any interim restriction and identify who can authorise a change in status. Do not allow an unresolved question to disappear when the procurement or project workflow advances.
- The specific functionality and intended setting.
- The concern and relevant provision being examined.
- Facts confirmed, facts missing and responsible reviewers.
- The decision, restrictions and evidence supporting it.
Connect the outcome to the system record.
If a proposed use cannot proceed, record the boundary clearly enough that it is not reintroduced under another project name. If a use is allowed within specific conditions, make those conditions visible to the operational owner and revisit them when the purpose changes.
EUAIC can help structure the screening and escalation record. The software workflow does not grant an exemption or permission to conduct a prohibited practice. Formal interpretation should be obtained from appropriately qualified advisers.