Security Risks and Compliance Considerations in EU Prohibited AI Practices

The EU AI Act (Regulation (EU) 2024/1689) defines prohibited AI applications under Article 5, restricting deployments that pose unacceptable risks to fundamental rights and governance. The regulation establishes legal constraints on AI systems that could violate privacy, enable mass surveillance, or introduce discriminatory practices.

On 4 February 2025, the European Commission published a guidance document clarifying the enforcement of Article 5. While the regulation remains unchanged, this document provides practical implementation insights on risk assessment, data integrity, and compliance measures for organizations developing AI.

Security Considerations in Article 5

1. Biometric Data Integrity & Dataset Risks (Article 5(1)(e))

The regulation prohibits large-scale facial image scraping from publicly accessible sources without consent. This restriction primarily addresses privacy violations and unauthorized biometric model training. The guidance document notes concerns regarding dataset integrity, as indiscriminate data collection can introduce unreliable inputs into AI models. By limiting unauthorized biometric data collection, the regulation reduces exposure to unverified dataset modifications and identity falsification risks.

2. Real-Time Biometric Identification Constraints (Article 5(1)(h))

The use of real-time biometric identification in public spaces is restricted, except under specific law enforcement exemptions (e.g., counterterrorism, missing persons cases). The guidance document highlights risks related to system reliability and accuracy, including concerns about misidentifications and manipulation techniques that could interfere with recognition models.

3. Emotion Recognition & Behavioral Analysis (Article 5(1)(f))

Emotion recognition AI is prohibited in workplaces and educational settings due to privacy concerns and potential risks of coercion or discrimination. The guidance specifies that AI models used for behavioral inference require careful oversight, as they can be misapplied in ways that impact decision-making, automated assessments, or psychological profiling.

Security Implications

• Data Integrity Protections: AI developers must implement data validation techniques and structured training datasets to mitigate unverified inputs and unreliable model outputs.
• Biometric System Safeguards: Organizations handling biometric authentication should apply cryptographic protections, including encryption for biometric templates and privacy-enhancing techniques to prevent unauthorized access.
• Authentication & Detection Measures: Systems relying on biometric authentication should integrate anomaly detection, verification mechanisms, and input consistency checks to reduce the risk of unauthorized use.

Regulatory Compliance & Enforcement

Non-compliance with prohibited AI applications under Article 5 may result in fines up to €35 million or 7% of global turnover. Organizations deploying biometric authentication, surveillance AI, or behavioral analytics must align with dataset integrity requirements and risk mitigation measures outlined in the European Commission’s 2025 guidance document.

📖 Reference: “EU Draft Guidelines on Prohibited Artificial Intelligence Practices (2025)” — A European Commission document providing enforcement guidance for Article 5 compliance. https://digital-strategy.ec.europa.eu/en/library/commission-publishes-guidelines-prohibited-artificial-intelligence-ai-practices-defined-ai-act

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