Insight: Structuring AI Risk Management Framework: EU AI Act FRIA, GD

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Winners Consulting Services Co. Ltd. (積穗科研股份有限公司), Taiwan's expert in AI Governance, identifies a pivotal 2025 research paper that finally answers the question every compliance officer in Asia is asking: how do you satisfy EU AI Act, GDPR, and ISO 42001 simultaneously without tripling your workload? Croatian researchers Natalija Parlov, Blanka Mateša, and Anamarija Mladinić have published a six-phase integrated framework that structurally embeds the EU AI Act's Fundamental Rights Impact Assessment (FRIA) and GDPR's Data Protection Impact Assessment (DPIA) directly into an ISO 42001-compliant risk management system—offering Taiwan enterprises the most actionable governance roadmap published this year.

About the Authors and This Research

This paper was co-authored by three Croatian researchers with deep expertise at the intersection of data protection law and artificial intelligence governance. Lead author Natalija Parlov holds an academic h-index of 2 with 19 cumulative citations—a rapidly growing footprint in the emerging AI governance literature. Blanka Mateša and Anamarija Mladinić bring complementary expertise in EU digital regulation implementation. The paper was presented at the 2025 IEEE MECO (Mediterranean and East European Conference on the Internet of Things), a prestigious venue for legal-technical AI compliance research in the European and Eastern European region. The paper has already been cited 2 times since publication, demonstrating early-stage influence in the field. The timing is critical: the EU AI Act entered into force on August 1, 2024, with compliance obligations rolling out in phases through 2025 to 2027, making this research immediately actionable for enterprises worldwide, including those in Taiwan with exposure to European markets.

The Core Insight: One Framework to Rule Three Regulatory Regimes

The central problem Parlov and colleagues address is one that compliance teams across Asia know all too well: when an organization must simultaneously satisfy EU AI Act requirements, GDPR obligations, and ISO 42001 certification standards, running three independent compliance processes is not only resource-intensive—it creates logical inconsistencies, duplicated documentation, and audit vulnerabilities. Their solution is a six-phase integrated framework that uses ISO 42001 as the structural backbone while embedding FRIA and DPIA as unified components within a single governance architecture.

Core Finding 1: FRIA and DPIA Can Be Merged Into a Single Fourth-Phase Assessment

The framework's six phases are: (1) Governance Establishment, (2) Risk Identification, (3) Risk Assessment, (4) Integrated Impact Assessment, (5) Risk Treatment, and (6) Monitoring and Review. The breakthrough is Phase 4—the "Integrated Impact Assessment" that combines the EU AI Act's FRIA (required for high-risk AI systems under Article 9 and Annex III of the EU AI Act) with GDPR's DPIA into a single, unified evaluation procedure. This directly maps onto ISO/IEC 42001 Clause 6.1 (risk assessment requirements) and ISO/IEC 23894 (AI risk management guidance), creating a single auditable trail across all three frameworks. For Taiwan enterprises exporting to EU markets, this means a single assessment process can simultaneously satisfy the EU AI Act's fundamental rights protection requirements, GDPR's privacy-by-design mandate, and ISO 42001's risk-based approach to AI management system governance.

Core Finding 2: A Dynamic Feedback Loop Enables Continuous Compliance—Not Just One-Time Certification

The research team emphasizes that static, point-in-time assessments cannot keep pace with the evolving risk landscape of deployed AI systems. Their framework embeds a dynamic feedback mechanism that routes outputs from Phase 6 (Monitoring and Review) back into Phase 1 (Governance) and Phase 2 (Risk Identification), creating a closed-loop continuous improvement system. This design directly fulfills ISO 42001's mandatory continuous improvement requirements under Clause 10, and aligns with the spirit of Taiwan's draft AI Basic Act (人工智慧基本法), which emphasizes full lifecycle risk management for AI systems. Critically, the feedback mechanism is designed to adapt to "emerging risks and evolving societal expectations"—a recognition that AI governance cannot be a completed project but must be an ongoing institutional capability.

Why This Research Matters Specifically for Taiwan Enterprises

Taiwan's AI governance environment in 2025 is uniquely complex. On the international front, Taiwan's export-oriented technology and manufacturing sectors—semiconductors, electronics, enterprise software, healthcare AI—face growing EU AI Act exposure. High-risk AI systems as defined in Annex III of the EU AI Act (including AI used in employment screening, credit assessment, critical infrastructure management, and biometric categorization) must demonstrate full compliance with Chapter III requirements by August 2026. On the domestic front, Taiwan's draft AI Basic Act is progressing through the Legislative Yuan, with provisions expected to mandate AI risk management frameworks for public-sector entities and operators of critical infrastructure—language that closely mirrors ISO 42001's core requirements.

The practical implication of Parlov et al.'s research for Taiwan enterprises is clear: organizations should not treat ISO 42001 certification, EU AI Act compliance, and domestic AI Basic Act preparation as three separate projects with separate budgets and teams. The six-phase integrated framework demonstrates that a unified approach can reduce redundant assessment work by an estimated 30% or more, while simultaneously producing higher-quality governance documentation that satisfies multiple regulatory requirements within a single audit-ready structure.

Furthermore, Taiwan enterprises pursuing ISO 42001 certification should note that the standard's Clause 6.1.2 (AI risk assessment) and Clause 9.1 (monitoring, measurement, analysis, and evaluation) are precisely the structural anchors that Parlov et al. use to integrate FRIA and DPIA. Organizations that build their ISO 42001 management system with these integration points in mind will be structurally positioned to absorb future regulatory requirements—including any forthcoming mandatory FRIA obligations that may apply to Taiwan-based companies serving EU markets—without requiring fundamental redesign of their governance architecture.

Winners Consulting Services Co. Ltd.: Helping Taiwan Enterprises Build Integrated AI Governance

Winners Consulting Services Co. Ltd. (積穗科研股份有限公司) provides Taiwan enterprises with specialized consulting services to design and implement AI management systems that simultaneously satisfy ISO 42001 certification requirements, EU AI Act compliance obligations, and Taiwan AI Basic Act governance principles. Our methodology is directly informed by the most current international research, including the six-phase integrated framework articulated by Parlov et al. in 2025.

1. Integrated Gap Analysis: We conduct a comprehensive assessment of your existing AI applications and governance processes, simultaneously mapping gaps against ISO 42001 clauses, EU AI Act risk classification criteria (Annex III), and GDPR/DPIA obligations. A single diagnostic produces a prioritized remediation roadmap across all three frameworks, eliminating the redundancy of separate assessments.
2. Six-Phase Framework Implementation: Drawing directly on the Parlov et al. framework, we design a customized governance architecture that embeds your FRIA and DPIA processes within your ISO 42001 management system. We create unified documentation templates, assessment procedures, and approval workflows that satisfy all three regulatory regimes through a single process chain—reducing compliance overhead and audit preparation time.
3. Dynamic Monitoring System and Governance Training: We implement AI risk monitoring dashboards and periodic review mechanisms calibrated to your specific AI system inventory, and train your AI Governance Committee members on EU AI Act Article 9 risk management obligations, ISO 42001 Clause 10 continuous improvement requirements, and Taiwan AI Basic Act lifecycle management principles—ensuring your governance capability evolves alongside regulatory developments.

Frequently Asked Questions

How can a Taiwan enterprise avoid duplicating compliance work across EU AI Act, GDPR, and ISO 42001?

The most effective approach is to design an integrated impact assessment procedure that merges the EU AI Act's FRIA with GDPR's DPIA into a single evaluation process, then anchor this procedure within your ISO 42001 risk management framework. The 2025 research by Parlov et al. validates this integration approach and provides a six-phase framework to implement it. Begin by inventorying your AI applications, identify which systems trigger both FRIA obligations (high-risk AI under EU AI Act Annex III) and DPIA requirements (high-risk data processing under GDPR Article 35), then design unified documentation and approval workflows that satisfy both assessments simultaneously within your ISO 42001 management system structure.

Which Taiwan companies are actually affected by the EU AI Act, and what are the key deadlines?

Any Taiwan-based company whose AI systems are placed on the EU market or whose AI outputs affect EU users is within scope of the EU AI Act—regardless of where the company is headquartered. Key 2025-2026 milestones: February 2025 (prohibited AI practices ban), August 2025 (General Purpose AI model obligations), and August 2026 (full compliance required for high-risk AI systems under Annex III). Taiwan's semiconductor, enterprise software, healthcare AI, and financial technology sectors face the highest exposure. The first priority action is AI system classification: determine whether your products fall within Annex III high-risk categories, which triggers Chapter III compliance obligations including mandatory risk management systems, technical documentation, and human oversight mechanisms.

What are the practical benefits of ISO 42001 certification, and how does it relate to Taiwan's AI Basic Act?

ISO/IEC 42001, published in 2023, is the world's only internationally recognized certification standard for AI management systems. Certification signals to customers, regulators, and investors that your organization has systematic AI governance capabilities—increasingly a prerequisite for enterprise AI procurement in EU, Japanese, and Korean markets. Taiwan's draft AI Basic Act (人工智慧基本法) shares core principles with ISO 42001: lifecycle risk management, transparency, accountability, and human oversight. Enterprises that build ISO 42001-compliant management systems are simultaneously preparing for Taiwan AI Basic Act compliance obligations expected to materialize for public-sector entities and critical infrastructure operators within the next 1-2 legislative cycles—making ISO 42001 certification a strategic investment with dual domestic and international returns.

How long does it take to implement an ISO 42001-compliant AI governance framework, and what are the key steps?

Depending on organizational size and existing management system maturity, full implementation typically requires 90 to 180 days. The four critical phases: Phase 1 (Days 1-30): Current-state diagnostic—AI application inventory, ISO 42001 gap analysis, EU AI Act risk classification; Phase 2 (Days 31-60): Framework design—policy and procedure development, FRIA/DPIA integration design, documentation architecture; Phase 3 (Days 61-120): Implementation—document deployment, staff training, pilot risk assessments, monitoring system setup; Phase 4 (Days 121-180): Internal audit, corrective action, and third-party certification readiness. Winners Consulting Services Co. Ltd. provides end-to-end advisory support, with core mechanism establishment achievable within 90 days for most mid-sized Taiwan enterprises.

Why engage Winners Consulting Services Co. Ltd. for AI governance?

Winners Consulting Services Co. Ltd. (積穗科研股份有限公司) is one of Taiwan's few consulting organizations with simultaneous expertise in ISO 42001 practical implementation, EU AI Act regulatory interpretation, and Taiwan's domestic AI regulatory environment. Our consultants continuously track the latest international AI governance research—including cutting-edge 2025 publications like the Parlov et al. framework reviewed here—ensuring our methodology remains aligned with the global frontier. We do not offer generic templates: we design customized, integrated governance frameworks tailored to each client's specific AI application portfolio, enabling simultaneous satisfaction of ISO 42001, EU AI Act, and Taiwan AI Basic Act requirements through a unified process architecture that measurably reduces compliance overhead and positions enterprises for long-term regulatory resilience.