Compliance
How to complete an Algorithmic Impact Assessment
The assessment is a scored questionnaire. The score decides who approves your system, whether a human has to make the final decision and how many experts review it before launch. Met late, it can force a redesign. Designing against it from the start costs far less.
The instrument
What the questionnaire contains
The Algorithmic Impact Assessment (AIA) is a mandatory questionnaire under the Treasury Board Directive on Automated Decision-Making (DADM). It has two halves that are scored separately.
The first half is 65 risk questions producing a raw impact score out of 169. The second half is 41 mitigation questions producing a mitigation score out of 77. The risk half is weighted towards data and towards impact on people, which is where the design decisions that move a score sit.
| Area | Questions | Maximum score |
|---|---|---|
| Data | 16 | 55 |
| Impact | 20 | 52 |
| Project | 10 | 22 |
| System | 9 | 17 |
| Algorithm | 9 | 15 |
| Decision | 1 | 8 |
| Total | 65 | 169 |
The 41 mitigation questions split into 4 on consultations, worth 10, and 37 on de-risking and mitigation, worth 67.
Source
Source: Algorithmic Impact Assessment tool, Treasury Board of Canada Secretariat, date modified 28 May 2026.
The arithmetic
The mitigation threshold is a cliff, not a slope
This is the single most useful thing to understand before you start answering questions, because it changes what you do in what order.
Mitigation does not reduce your score proportionally. If the mitigation score reaches 80 percent or more of the maximum attainable mitigation score, the tool deducts 15 percent from the raw impact score. Below that threshold, it deducts nothing and the current score equals the raw impact score.
Eighty percent of 77 is 62. A project sitting at 61 gets no credit for any of it. The same project at 62 drops 15 percent of its raw impact score in one step. A project near a level boundary can change level on mitigation evidence alone, without the system changing at all.
What score produces which impact level?
| Level | Score | Described as |
|---|---|---|
| Level I | 0 to 25 percent | Little to no impact |
| Level II | 26 to 50 percent | Moderate impact |
| Level III | 51 to 75 percent | High impact |
| Level IV | 76 to 100 percent | Highest impact |
Two consequences follow for delivery. Answer the mitigation half early enough to know whether 62 is reachable, because if it is not, the effort spent on partial mitigation buys no score. And treat the data and impact sections as design inputs rather than as a form filled in at the end, because together they carry 107 of the 169 available points.
What the level costs you
Where the requirements step up
Peer review and the explanation requirement step up from Level I to Level II. The larger step change is at II to III, and it is three things at once.
| Requirement | Level I | Level II | Level III | Level IV |
|---|---|---|---|---|
| Peer review | Not required | At least one qualified expert | At least one qualified expert | At least two qualified experts |
| Final decision | May be automated | May be automated | Must be made by a human | Must be made by a human |
| Explanation to the client | General explanation published | Plus a detailed explanation with any decision | Plus a detailed explanation with any decision | Plus a detailed explanation with any decision |
| Training | Role-based, high level | Role-based, high level | Recurring and operational | Recurring and operational |
| Approval to operate | Assistant deputy minister | Assistant deputy minister | Deputy head | Treasury Board |
Read the approval row before the peer review row. A Level III project usually takes longer because a deputy head has to sign, and a Level IV project needs Treasury Board; the reviewer is rarely the cause. Those are calendar items owned by your institution rather than by a supplier, and they belong in a plan before anyone writes code.
Note also what does not change. Peer review is one expert at both Level II and Level III. Two experts is a Level IV requirement, and it should not be read as a Level III one.
Source
Sources: Directive on Automated Decision-Making, and the Guide to Peer Review of Automated Decision Systems, date modified 24 June 2025.
Sequence
Two completions, three published artifacts, all before launch
The assessment is not a one-time gate at the end. Treating it as one is the most expensive scheduling mistake available on these projects.
- Complete it once at the beginning of design. The score at this point tells you which approval authority you are heading for and whether the design needs to change to avoid a level you cannot resource.
- Book the peer review during design, not after acceptance. The guide suggests budgeting one to three months, and recommends running it after privacy and security assessments are complete or underway.
- Complete it a second time before production. The two completions are separate by design, so a score that moves between them is expected rather than a finding.
- Publish three things before the system launches. First, the assessment results on the Open Government Portal, in both official languages and in an accessible format. Second, the peer review report or a justified plain-language summary of it. Third, the plain-language notice through every service delivery channel in use.
- Update it when scope or functionality changes. The Directive requires review, approval and update on a scheduled basis and when the system changes.
Who can act as a peer reviewer?
Eligible reviewers include experts from a federal, provincial or municipal government institution and faculty at a post-secondary institution. Researchers at civil society organizations also qualify, as do third-party vendors and individuals at other external organizations. So do members of a data and automation advisory board specified by the Treasury Board Secretariat. Reviewers disclose conflicts of interest, and the guide recommends choosing experts external to your own department and avoiding reciprocal reviews between departments. Hiring a firm is one route. It is not the only one.
Scope
Internal services are in scope, which is easy to miss
The third review of the Directive, effective 25 April 2023, expanded scope to internal services, naming hiring, performance management and security screening of employees. The scope guide gives resume screening and skills-based assessment tools as in-scope examples. A hiring tool used on public servants is an administrative decision about a client in the sense the Directive means.
The same amendments required institutions to publish the assessment before launch rather than after. They also required institutions to make peer review findings public, in full or as a summary, before launch. Compliance deadlines were 25 October 2023 for new systems and 25 April 2024 for existing ones.
Source
Source: Amendments to the Directive on Automated Decision-Making, date modified 8 October 2024.
Honesty
What this article does not establish
- A fourth review of the Directive is under way and its outcome is not published here. A Treasury Board note dated 19 June 2025 called the review nearly complete. The third review of April 2023 remains the operative amendment as far as we can verify. Check the Directive. Do this before relying on any requirement in this article for a live project.
- We are not a peer reviewer for systems we build. A reviewer assesses the accuracy of the assessment and the readiness of the system, and cannot be the party that delivered it. Where we deliver, the peer review is somebody else's work.
- This is not legal advice or a compliance opinion. The institution that operates a system determines its impact level using the tool, and the authority named in the table above approves it.
Next step
Screen one workflow before it reaches architecture
A 30-minute fit check covers whether the Directive applies to your candidate workflow, roughly where it would score, and which approval authority that points at. You keep the notes either way.