I think its right that a risk to "rights and freedoms" does not necessarily equate to actual damage.
If it did we would have the odd, and surely unintended, situation that GDPR by design allows you not to report such to the subject.
On the other hand a "high risk", which is the criterion for reporting to the subject, may well do. Certainly all of the A29WP examples of requiring a report to the subject seem to be cases where a claim for damages, albeit modest in some cases, would stand up.
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