The prohibition in Article 5(1)(e) AI Act covers AI systems used to create or expand facial recognition databases. ‘Database’ in this context should be understood to refer to any collection of data, or information, that is specially organized for rapid search and retrieval by a computer. A facial recognition database is capable of matching a human face from a digital image or video frame against a database of faces , comparing it to images in the database and determining whether there is a likely match between the two. Such a facial recognition database may be temporary, centralised or decentralised. Article 5(1)(e) does not require that the sole purpose of the database is to be used for facial recognition; it is sufficient that the database can be used for facial recognition.
guidance
Prohibitions § 6.2.1
(226)