Where do GDPR and the EU AI Act overlap?
GDPR and the EU AI Act overlap wherever an AI system processes personal data. This includes data governance requirements, risk assessment obligations, transparency duties, human oversight expectations, and documentation requirements.
The two regimes serve different purposes — GDPR protects data subjects, the AI Act governs AI system risk — but they create overlapping evidence and governance obligations that must be managed together, not in parallel silos.
Key points
- Both regimes require risk assessment, but a DPIA (GDPR Art. 35) and an AI risk assessment (AI Act Art. 9) are distinct obligations with different scopes and outputs.
- Transparency requirements overlap but differ: GDPR requires informing data subjects, the AI Act requires technical transparency about AI system behaviour.
- Data governance under the AI Act (Art. 10) adds AI-specific requirements on top of GDPR data processing obligations.
- A single AI system may require compliance records for both regimes. Managing them separately creates duplication and inconsistency risk.
Why it matters
Organizations that manage GDPR and AI Act compliance in separate processes risk creating inconsistent records, duplicated effort, and governance gaps at the intersection. A DPO reviewing personal data processing and a compliance officer reviewing AI risk classification may reach different conclusions about the same system. Integrated governance ensures both perspectives are connected in the same record.
How EAB approaches this
EAB's GDPR–AI Act Bridge connects AI governance records with GDPR processing records. The GDPR Module manages processing activities, DPIAs, and TOM profiles. The bridge ensures that a system governed under the AI Act and involving personal data has connected evidence across both regulatory frameworks.