The EU Artificial Intelligence Act (“AI Act”) changes how organisations—including small nonprofits—can use AI tools. Understanding the new rules is essential for compliance and responsible use.
NGO / NPO Compliance Checklist under the EU AI Act
⚙️ What the AI Act does
- The AI Act entered into force 1 August 2024. (Wikipedia)
- It introduces a risk-based classification of AI systems: “unacceptable,” “high risk,” “limited risk,” and “minimal risk.” (ePRNews)
- For “general-purpose AI” (GPAI) models — e.g. large language models, image generators — special transparency, copyright, and disclosure rules apply. (ePRNews)
- Some prohibitions took effect 2 February 2025 — for example, AI practices deemed “unacceptable risk,” like unconsented biometric surveillance or manipulative social scoring. (nccgroup.com)
- The stricter rules for “high-risk” AI deployers and providers apply gradually, with key deadlines in 2025–2027. (EY)
Who the rules apply to — and why your NGO might be included
The AI Act covers a wide range of actors:
- “Providers” — those who develop or supply AI systems
- “Deployers” — those who use AI systems. If your NGO uses AI tools (for example, for recruitment, content generation, translation, data analysis, or donor screening), you likely count as a deployer. (europeanaifund.org)
- The regulation applies regardless of where your software comes from — if you deploy or make an AI system available to EU-based people, the law applies. (PwC)
This means small nonprofits are not exempt — using a popular online AI tool could trigger compliance obligations.
What obligations NGOs should watch out for
Depending on how you use AI, different rules may apply:
| Use case / AI system | What the law requires |
|---|---|
| Internal support tools, e.g. generative AI for translations, scripts, drafting copy, data cleaning | Might fall under GPAI rules — transparency obligations if content is published or shared externally (Noerr) |
| AI for decision-making (e.g. screening applicants or allocating aid) | If classified “high-risk,” must meet strict requirements: documentation, human oversight, transparency, risk management (European Parliament) |
| Use of or providing AI systems that allow disallowed practices (e.g. biometric ID, profiling, social scoring) | These are banned under “unacceptable risk.” Use would be illegal. (European Parliament) |
| Publishing AI-generated content (text, images, video) | You must label it as AI-generated. Transparency rules apply. (Noerr) |
What it means for small nonprofits — practical takeaways
- If you only use low-risk AI (e.g. for ordinary office tasks, simple translations, content drafting), compliance should be minimal. Most common tools fall under “limited risk.”
- If you publish AI-generated content, make sure you clearly state that it was AI-generated.
- If you use AI for decisions affecting people (e.g. applicant screening, aid eligibility), you must treat it like a “high-risk system”: keep documentation, ensure human oversight, avoid bias.
- Avoid any AI tools or practices that could be “unacceptable risk” (biometric surveillance, profiling, social scoring).
- Build internal awareness. Even if you are a small team, define who “deploys” AI and how. Assign responsibility.
Why the AI Act matters for social impact organisations
- Ethical mission: NGOs often work with vulnerable communities. The AI Act enshrines respect for rights, non-discrimination, and transparency.
- Trust: Transparent use of AI helps maintain public and donor trust.
- Accountability: Mistakes or misuse — especially in allocations, decision-making, or outreach — can now carry legal risk.
- Growth and compliance: As your organisation grows or collaborates across borders, compliance ensures you can continue operations without regulatory friction.
If you like, I can draft a short NGO-friendly compliance checklist (5–10 steps) to help meet the AI Act obligations while using AI tools — that’s often helpful for small teams.
