Normative Considerations on Impact Assessments in EU Digital Policy

This paper assesses the increased normative role of impact assessments in the EU digital governance. We first investigate how impact assessments have gained prominence as regulatory tools in regulating the digital dimension. Then, we analyse, also from a comparative perspective, three different impact assessment models enshrined in EU legal acts (i.e., the GDPR, the AI Act and the DSA). Finally, we highlight six shortcomings common to the previously addressed models.