What is the AI Assessment Framework?

The European AI Regulation (also known as the AI Act) is the new European law that sets rules for the development and use of AI systems. The law has direct implications for every organization that uses AI, including schools.

The AI Assessment Framework translates that legislation into educational practice. It helps school boards and suppliers provide concrete answers to three questions:

1. Does my system even fall under the AI Regulation?
2. If so, what risks does it pose?
3. What measures do I need to take?

Without this framework, you would have to sift through the European legislation yourself and translate it to your specific situation. That's a significant task. The assessment framework takes that work off your hands.

Who is it for?

The assessment framework primarily targets suppliers of IT systems with AI. They are primarily responsible: they must determine whether their product falls under the AI Regulation and what steps they need to take. But also schools and school boards have a role to play here. Because if a supplier provides a high-risk AI system, the school itself must also take additional measures. So, you cannot place the entire responsibility on the supplier.

And there's an extra consideration that many schools overlook. Imagine: a teacher uses ChatGPT and configures it to automatically assess whether a student is ready for the next module. That sounds like a clever use of an existing tool, but in the eyes of the law, that teacher has just created a new AI system. And therefore, the school is considered a provider of that system, with the same obligations as a software supplier.

Four steps of the assessment framework

The assessment framework uses a logical step-by-step approach. This way, you always know exactly where you stand.

Step 1: Does the system fall under the AI Act?

Not every system with some automation qualifies as an AI system under the law. The first step is to determine if your system meets the definition. The assessment framework explains precisely what that definition entails.

Step 2: Is it a prohibited application?

Some AI applications are simply not permitted. This includes systems that influence behavior in ways that undermine human autonomy.

Step 3: Is it a high-risk application?

This is the step most school boards should pay close attention to. The AI Act defines several categories as 'high-risk'. Specifically for education, this includes:

• AI systems for admission to (vocational) education (e.g., student selection: who do we admit?)
• AI systems for evaluating learning outcomes
• AI systems for assessing students' educational level
• AI systems for monitoring students during exams

Does your school or supplier use one of these applications? If so, additional obligations apply to both the supplier and the school.

Step 4: Are there any exceptions?

Not every application that appears high-risk at first glance truly falls into that category. There are exceptions. The assessment framework helps you determine if your situation falls under such an exception. Based on these four steps, you will know exactly which measures you need to take, and which you don't.

Legislation in development

One important caveat: the AI Act is new, and its precise implementation is not yet clear on all points. Supervision of high-risk AI systems will begin in August 2026, and the AI Act is expected to be fully in force by August 2027. SIVON and Kennisnet actively maintain the assessment framework and will update it as soon as new legislation or clarifications become available. This also means: don't just look at this topic once and then forget about it. Just like with the GDPR and ISO 27001, compliance is not a snapshot, but a continuous process.

What should you do now?

Whether you're a school administrator or an educational software provider, it's wise to take action now. Don't wait for the law to be fully developed; instead, start by identifying which AI systems you use or supply and whether they fall under the regulation.

Specifically:

• School Boards: Identify which AI systems you use. Actively ask suppliers about their compliance assessment with the AI Regulation. Be aware of high-risk applications, as these require additional mandatory measures.
• Suppliers: Review the assessment framework for every product with AI functionality. Document your assessment and the measures you are implementing.
• Everyone: Stay informed about updates to the assessment framework – the law is still evolving.

Need help with the EU AI Act?

You don't have to navigate the AI Regulation and AI Assessment Framework alone. At Fendix, we help organizations, both within and outside the education sector, understand and implement AI legislation – from initial inventory to establishing the right processes.

Want to know what the AI Act means for your organization? Schedule a no-obligation consultation, and we'll review your specific situation together.

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