Versatile AI Risk Assessment
Biometrics and emotion recognition

Emotion recognition

The system infers a person's emotions or intentions from their face, voice or behaviour.

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A concise PDF covering how the system works, its data flows and points to investigate, ready to share.

The explanations and measures describe the typical system design. Extensive personal changes add an appendix.

Understand the use case

What defines this use case?

Trials have taken place at UK railway stations and in an EU research project at border crossings.

This page describes a typical system design. Actual data flows and permissions depend on your implementation.

System design
Analysis and processing
Ability to act
Action permissions depend on integration
Fields of use
transport operators, border control
Also known as
emotion analysis from faces or voices

How it works, step by step

System design and data flows

  1. Input data

    The system receives camera images, voice recordings or other bodily signals from a person.

    The system analyses images and voices of people who control their own behaviour and can disguise it. Some systems analyse face and voice together; others use only one.

  2. Processing

    The model recognises expressions, tone or movement and infers an emotion such as joy, anger or fear, or an intention such as deception.

    The model processes characteristics of the face, voice or other signals and assigns an emotion category or assessment. It thus infers a state that cannot be observed directly from external signals. The resulting category is a model interpretation rather than a direct measurement of subjective experience.

  3. Results

    The system assigns an emotion and numerical score to each person or group.

    The result describes the defined model task. A match, category or forecast acquires its professional significance only in conjunction with the underlying data and intended use.

  4. Use and impact

    The output feeds into analysis or influences how workers, customers or travellers are treated.

    Integration determines whether the result is simply displayed, adopted after approval or written directly into a business application. These variants differ in their data flows and permissions.

Explore the system design: Select a component to see its task, incoming and outgoing data, and role in the use case. The guided walkthrough explains each phase. Then use Yes, Uncertain and No to represent your specific system variant.

How the system is built

7 review first10 clarify7 baseline threats

InputProcessingResultImpact Externalaccess 04 Input 41 Third-partycontent 00 AI model 00 Providerservice 12 Documentcollection 00 Memory 00 Training andfeedback 11 OtherAI agents 00 Tools andinterfaces 00 Result 00 Business appor equipment 01 person 10 Affectedperson 00 AI serviceswithout approval 01 Externalaccess 04 Input 41 Third-partycontent 00 AI model 00 Providerservice 12 Documentcollection 00 Memory 00 Training andfeedback 11 OtherAI agents 00 Tools andinterfaces 00 Result 00 Business appor equipment 01 person 10 Affectedperson 00 AI serviceswithout approval 01
  • Present
  • Depends on your system
  • Absent
  • Review first
  • To clarify

In this system design: 7 to review first, 10 to clarify, 7 baseline threats.

Architecture as a list

How it differs from similar use cases

Data and information

Input data and information sources

The system analyses images and voices of people who control their own behaviour and can disguise it. The system processes identifiable people's faces or voices.

Processing and operating environment

Deployers use ready-made services, such as Amazon Rekognition at Network Rail.

Storage and further use

Logging, retention periods and possible use for training must be established for the specific implementation.

Results and data sharing

If a cloud service analyses the images, they leave the organisation's environment.

Using a provider does not automatically determine where processing takes place. Storage location, subcontractors, deletion periods and use for training must be checked for the specific deployment.

Assess risks and determine measures

From understanding the system to analysing risks

  1. Define the system boundary

    Record data, participants, interfaces and permissions. Resolve uncertain characteristics in the model.

  2. Investigate threats

    Relate review candidates to actual data flows: what could happen, and who would be affected?

  3. Assess risk

    Assess impacts and likelihood in the deployment context. The number of review candidates is not a risk score.

  4. Provide evidence of measures

    Select appropriate controls, assign responsibilities and define effectiveness checks. Document residual risks and approvals.

Key threats in the application context

  • 3 particularly important
  • 4 typical
  • 10 depending on the system
  • 7 additional threats for every AI system

A total of 24 threats from the threat catalogue may be relevant to this use case.

Priority review points

  1. Overreliance

    Facial expressions do not reliably reveal feelings and differ across cultures and individuals. Trusting the output may label a tense traveller suspicious or a calm worker unmotivated.

  2. Adversarial Inputs

    People can deliberately control their expressions and tone when they know they are observed. The system then attributes calmness or honesty where neither exists.

  3. Sensitive Information Disclosure

    The system records its attributed emotion for each recording. If these labels leak with an image or name, individuals' supposed moods, fears or intentions become known.

4 further review candidates in the typical design

Other relevant threats

  1. Targeted Poisoning / Label Poisoning

    Falsified training labels can deliberately shift model outputs.

    Listed because of this characteristic

    • Learns from examples with correct answers
  2. Backdoor ML Model

    Training data or an adopted base model can introduce hidden triggers for misbehaviour.

    Listed because of this characteristic

    • Uses another provider's model
  3. Privacy Attacks

    Targeted queries can recover some personal or protected training data from the model.

    Listed because of these characteristics

    • Processes personal data
    • Processes confidential data
    • Recognises or compares people by physical features
  4. Exfiltration from ML Application

    Protected data can leak through tools, network connections, storage or insiders.

    Listed because of this characteristic

    • Processes confidential data

Up to 10 further threats may apply, depending on your system design. Nine threats need to be reviewed for every AI system. Two of these are particularly important here and are therefore listed above.

System features and open questions

Each Yes adds further threats to your checklist, up to 10 in total. If you cannot yet answer a question, include its threats in your review.

How many threats a Yes adds
  • Added by this Yes
  • Also requires a Yes to another question

How your system is built

  1. Processes text, images and speech together2 threats
  2. Learns from your own data1 threat, plus 1 only in combination with other characteristics
  3. Changes data or triggers processes1 threat
  4. Uses operational feedback1 threat

How your system is built

Can the system change things itself, such as storing data, sending messages, initiating transactions or granting permissions?

If yes, add

Does the system process several input types together, such as text with images or speech?

Some systems analyse face and voice together; others use only one.

If yes, add

How you operate the system

These questions arise for almost every AI system.

Controls and implementation

Measures for the priority review areas are expanded. Each linked measure explains how to implement it.

Controls for the remaining threats are available on their pages in the threat catalogue.

AI Act provisions

When AI Act provisions apply
  1. Art. 4: AI literacy

    For every AI system Applies since 2 February 2025.

  2. Art. 5 para. 1 point e, f, g, h: Prohibited biometric practices

    In typical use Review trigger since 2 February 2025.

  3. Art. 50 para. 3: Disclosure of emotion recognition and categorisation

    Depending on use Review trigger since 2 August 2026.

  4. Annex III no. 1 point c: Emotion recognition

    In typical use Review trigger from 2 December 2027.

  5. Annex III no. 7: Migration, asylum and border control

    Depending on use Review trigger from 2 December 2027.

Applies to every AI system

Art. 4: AI literacy

Applies if staff or appointed representatives operate or use AI systems.

Applies since 2 February 2025.

Obligations and details for Art. 4: AI literacy
Who bears the obligations
Provider, Deployer, Product manufacturer, Provider of a general-purpose AI model

Detailed obligations

May apply in typical use

Art. 5 para. 1 point e, f, g, h: Prohibited biometric practices

Applies if the system recognises workers' emotions in the workplace or learners' emotions in an educational institution, except where used for medical or safety reasons.

Applies since 2 February 2025.

Obligations and details for Art. 5 para. 1 point e, f, g, h: Prohibited biometric practices
The general condition is
Applies if the system indiscriminately collects facial images from the internet or video, recognises workplace or educational emotions, categorises people biometrically by sensitive attributes, or identifies people in public spaces in real time for law enforcement.
Exception
Workplace and educational emotion recognition is permitted for medical or safety reasons. Real-time law enforcement identification has narrowly defined exceptions.
Who bears the obligations
Provider, Deployer, Importer, Distributor, Authorised representative, Product manufacturer, Provider of a general-purpose AI model

Detailed obligations

Annex III no. 1 point c: Emotion recognition

Applies if the system infers emotions or intentions from the faces, voices or bodily signals of people other than workers or learners, such as travellers or telephone customers.

Applies from 2 December 2027.

Obligations and details for Annex III no. 1 point c: Emotion recognition
The general condition is
Applies if the system infers emotions or intentions from faces, voices or bodily signals.
Who bears the obligations
Provider, Deployer, Product manufacturer

Detailed obligations

May apply in particular uses

Annex III no. 7: Migration, asylum and border control

Applies if authorities use the system at borders or in asylum procedures to detect deception, as trialled by the iBorderCtrl research project.

Applies from 2 December 2027.

Obligations and details for Annex III no. 7: Migration, asylum and border control
The general condition is
Applies if the system is used in examining asylum, visa or residence applications or at border controls.
Who bears the obligations
Provider, Deployer, Product manufacturer

Detailed obligations

Art. 50 para. 3: Disclosure of emotion recognition and categorisation

Applies if people are exposed to the system, for example at a station or during a customer conversation.

Applies since 2 August 2026.

Obligations and details for Art. 50 para. 3: Disclosure of emotion recognition and categorisation
The general condition is
Applies if the system recognises emotions or categorises people biometrically.
Who bears the obligations
Deployer

Detailed obligations

Classify your system with the quick checker All obligations in the obligations compass

Cross-cutting threats

Review these threats for every AI system, whatever its purpose.

Why these threats always belong on the checklist

Atypical system features

View 16 further questions

If any of these features does apply to your system, add the listed threats.

Sources

Related use cases

Also in the field of Biometrics and emotion recognition

Often used together with

Updated: 30 September 2026. Review checklist rules version 0.3.2, threat catalogue version 2026.10.24.2. How these pages are structured