How to Run a Multi-Layered Impact Assessment in 2025 (GDPR, DSA, AIA)
Is your organization struggling to manage multiple regulatory impact assessments? You’re not alone. With the evolving European digital regulatory landscape, conducting multi-layered impact assessments has become essential for compliance in 2025.
Organizations now face the challenge of complying with overlapping frameworks—GDPR, DSA, and the AI Act—each with its own impact assessment requirements. This “silent revolution” has transformed how we approach risk assessment and compliance.
In this comprehensive guide, we’ll show you how to efficiently conduct multi-layered impact assessments that satisfy all regulatory requirements while saving time and resources.
The Multi-Layered Impact Assessment Challenge
When dealing with digital services and AI systems in the EU, your organization likely needs to juggle multiple impact assessments simultaneously:
- Data Protection Impact Assessment (DPIA) under GDPR Article 35
- Risk Assessment under DSA Article 34
- Risk Assessment under AI Act Article 9
- Fundamental Rights Impact Assessment (FRIA) under AI Act Article 27
Implementing an effective multi-layered impact assessment strategy has become a critical compliance priority for organizations operating in Europe.
Understanding the Different Impact Assessment Types
GDPR Data Protection Impact Assessment (DPIA)
When required: For high-risk data processing operations that are likely to result in high risk to individuals’ rights and freedoms.
Key components:
- Description of the processing operations
- Assessment of necessity and proportionality
- Risk assessment (focusing on rights and freedoms)
- Measures to address identified risks
Risk definition (Recital 75 GDPR): “The risk to the rights and freedoms of natural persons, of varying likelihood and severity, may result from personal data processing which could lead to physical, material or non-material damage, in particular: discrimination, identity theft… or any other significant economic or social disadvantage.”
DSA Risk Assessment
When required: For Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs).
Key components:
- Systemic risks related to illegal content
- Negative effects on fundamental rights
- Potential impacts on civic discourse, electoral processes, and public security
- Consideration of gender-based violence, public health, and minor protection
Risk definition (Article 34 DSA): “Actual or foreseeable negative effects for the exercise of fundamental rights, in particular Articles… of the Charter.”
AI Act Risk Assessment and FRIA
When required:
- Risk assessment: For providers of high-risk AI systems
- FRIA: For deployers of high-risk AI systems that are public authorities, provide public services, or are in the banking/insurance sector
Key components of AI Risk Assessment:
- Detailed documentation of system functionality
- Foreseeable unintended outcomes
- Risk assessment for health, safety, fundamental rights, and discrimination
Key components of FRIA:
- Description of AI system use and context
- Categories of affected individuals
- Specific risks of harm
- Human oversight measures
- Risk mitigation strategies
Risk definition (Article 7 AIA): “A risk of harm to the health and safety, or a risk of adverse impact on fundamental rights.”
Creating a Multi-Layered Impact Assessment Approach
Rather than conducting separate assessments for each regulatory framework, smart organizations are developing integrated multi-layered impact assessment methodologies that maximize efficiency while ensuring comprehensive compliance. This approach not only saves resources but also provides a more holistic understanding of risks and impacts.
Step 1: Mapping Requirements and Identifying Overlaps in Your Multi-Layered Impact Assessment
The first step in creating an effective multi-layered impact assessment is to map all applicable requirements across frameworks:
Assessment Framework Comparison:
GDPR (DPIA)
- Purpose: Data protection
- Risk focus: Rights and freedoms
- Documentation: Processing activities
- Mitigation: Technical and organizational measures (TOMs)
DSA Risk Assessment
- Purpose: Online platform safety
- Risk focus: Systemic harms
- Documentation: Platform design
- Mitigation: Platform controls
AI Act Risk Assessment
- Purpose: AI system safety
- Risk focus: Health, safety, rights
- Documentation: AI system design
- Mitigation: AI system safeguards
AI Act FRIA
- Purpose: Fundamental rights protection
- Risk focus: Fundamental rights
- Documentation: Deployment context
- Mitigation: Deployment safeguards
Identify overlapping areas where a single multi-layered impact assessment activity can serve multiple compliance needs, creating efficiency while maintaining thoroughness.
Step 2: Establish a Multi-Disciplinary Team
A successful multi-layered assessment requires diverse expertise:
- Data Protection Officer/Privacy Team: GDPR expertise
- Tech/Engineering Team: System architecture and technical understanding
- Legal Team: Regulatory interpretation and compliance
- Business Units: Operational context and business requirements
- Human Rights Experts: Fundamental rights considerations
- Ethics Committee: Ethical implications assessment
Step 3: Create a Unified Assessment Template
Develop a comprehensive template that captures all required elements across frameworks. Structure it to avoid duplication while ensuring all regulatory requirements are met:
- Project & System Description
- Nature, scope, context of processing/system
- Technical specifications and data flows
- Deployment context and use cases
- Data Mapping & Processing Activities
- Personal data involved
- Data subjects affected
- Processing operations
- Data retention periods
- Cross-border transfers
- Legal & Compliance Analysis
- Legal bases for processing
- Applicable regulatory frameworks
- Prior consultations (if required)
- Risk Assessment
- Health and safety risks
- Personal data protection risks
- Fundamental rights impacts
- Societal and environmental impacts
- Probability and severity assessment
- Special considerations for vulnerable groups
- Mitigation Measures
- Technical measures
- Organizational measures
- System design adaptations
- Deployment safeguards
- Monitoring mechanisms
- Documentation & Governance
- Assessment sign-off process
- Review schedule
- Incident response plan
- Stakeholder consultation outcomes
Step 4: Implement a Staged Assessment Process
Multi-layered assessments are most effective when conducted in stages:
Preliminary Screening
- Determine which assessments are legally required
- Identify key risk areas that need detailed analysis
- Establish assessment scope and limitations
Detailed Assessment
- Apply the unified template
- Engage all relevant stakeholders
- Document evidence of compliance considerations
Review & Validation
- Cross-check against specific regulatory requirements
- Verify all mandatory elements are addressed
- External validation (when necessary)
Implementation & Monitoring
- Implement agreed mitigation measures
- Establish monitoring procedures
- Define reassessment triggers
Practical Example: Multi-Layered Assessment for an AI-Powered Content Moderation Tool
To illustrate this approach, let’s consider a practical example of a Very Large Online Platform implementing an AI-powered content moderation system.
Assessment Trigger Points
This scenario triggers multiple assessment requirements:
- GDPR DPIA: Processing special categories of data at scale
- DSA Risk Assessment: Platform systemic risk consideration
- AI Act Risk Assessment: High-risk AI system (Annex III)
- AI Act FRIA: Public-facing critical infrastructure application
Integrated Assessment Approach
A multi-layered assessment would:
- Document the AI system and its integration with the platform
- Technical specifications (model architecture, training data sources)
- Decision-making process
- Human oversight mechanisms
- Data flows and retention policies
- Identify affected individuals and rights
- Platform users
- Content creators
- Potentially vulnerable groups
- Specific fundamental rights implications
- Conduct comprehensive risk assessment
- False positive/negative content classifications
- Potential discrimination or bias
- Chilling effects on free expression
- Impacts on civic discourse
- Data protection implications
- Develop mitigation strategy
- Technical safeguards
- Algorithmic transparency measures
- Human review processes
- User redress mechanisms
- Monitoring and auditing protocols
- Document ongoing compliance measures
- Regular testing for bias or discrimination
- Periodic reassessment triggers
- Incident response procedures
- Continuous improvement plan
Best Practices for Conducting Multi-Layered Impact Assessments
1. Document Everything
Maintain comprehensive records of assessment processes, methodologies, findings, and mitigation decisions. This documentation is vital for demonstrating compliance with all applicable frameworks.
2. Embrace Technological Solutions
Use GRC (Governance, Risk, and Compliance) tools to streamline the assessment process, centralize documentation, and track mitigation implementation.
3. Stay Current with Regulatory Developments
Regulatory interpretations continue to evolve. Monitor guidance from authorities like the EDPB, European Commission, and national regulators to ensure your assessment methodology remains compliant.
4. Conduct Regular Reviews
Multi-layered assessments shouldn’t be one-time exercises. Establish a schedule for periodic reviews, especially when:
- Significant system changes occur
- New use cases are implemented
- Regulatory frameworks are updated
- Operational contexts shift
5. Engage with External Expertise
Consider involving external experts to validate your assessment methodology and findings, particularly for high-stakes applications where independent verification adds credibility.
Challenges and Solutions
Challenge: Resource Constraints
Solution: Prioritize assessments based on risk level and gradually build internal expertise through training and knowledge sharing.
Challenge: Overlapping Requirements in Multiple Frameworks
Solution: Create a comprehensive mapping of all requirements and identify where one multi-layered impact assessment activity can satisfy multiple obligations efficiently.
Challenge: Rapidly Evolving Regulatory Landscape
Solution: Establish a regulatory monitoring system and build flexibility into assessment templates to accommodate new requirements.
Challenge: Organizational Silos
Solution: Create cross-functional working groups with clear responsibilities and communication channels.
Why Multi-Layered Impact Assessments Are Essential in 2025
The evolving European regulatory landscape demands a sophisticated approach to impact assessments. By adopting a multi-layered impact assessment methodology, organizations can efficiently address the requirements of the GDPR, DSA, and AI Act while maintaining a holistic view of risks and mitigation strategies.
This integrated multi-layered approach delivers several key benefits:
- Efficiency: Streamline assessment processes by identifying overlapping requirements
- Consistency: Ensure harmonized risk evaluation across different regulatory frameworks
- Resource optimization: Reduce duplicative efforts and assessment fatigue
- Strategic insights: Gain a more comprehensive understanding of system impacts
- Proactive compliance: Address emerging requirements before they become mandatory
In 2025’s complex regulatory environment, the ability to conduct effective multi-layered impact assessments has become a critical organizational capability that separates compliance leaders from those struggling to keep pace.
Need expert guidance on conducting multi-layered impact assessments for your organization? Our team specializes in navigating the complex intersection of GDPR, DSA, and AI Act requirements. Contact us to learn more about our multi-layered impact assessment templates, methodologies, and consulting services.
