The EU AI Act for HR & recruitment teams

If your HR team uses AI to source, screen or rank candidates — or to help decide on promotions, task allocation or performance — you are in one of the EU AI Act's explicitly high-risk categories. Annex III, point 4 names employment and recruitment directly. Here is what that means for an HR or talent team, in plain English.

Why HR AI is high-risk

Annex III(4)(a) covers AI systems used for recruitment or selection — placing targeted job ads, filtering applications, and evaluating candidates. Point 4(b) extends to AI that informs decisions on terms of work, promotion or termination, task allocation, and monitoring worker performance. The logic is simple: these systems shape people's access to work, so a biased or opaque model does real harm. That puts most AI-powered ATS filtering, CV-ranking, video-interview scoring and workforce-analytics tools squarely in high-risk territory.

What you have to do

• Know your role. If you buy an AI recruiting tool, you are a deployer; the vendor is the provider. If you build or heavily customise one under your own name, you may become a provider yourself.
• Human oversight (Article 14 & 26).A human must be able to review and override the AI — no fully automated reject/hire on the model's say-so.
• Transparency to candidates. Inform the people subject to the system that AI is used in the decision.
• Bias & accuracy checks. Deployers must use the system per instructions and monitor it; providers must test for discriminatory outcomes across protected groups.
• Records. Keep logs and, for providers, the Annex IV technical documentation.

The GDPR's Article 22 (automated decisions) already applies to much of this — the AI Act layers governance obligations on top.

Deadlines

High-risk obligations for Annex III systems were rescheduled under the Digital Omnibus to 2 December 2027. That is not a reason to wait — HR AI procurement cycles are long, and enterprise clients and works councils increasingly ask for AI Act evidence now. The full timeline is in our deadlines guide.

Where to start

Confirm which of your HR tools are actually in scope and at what tier with the free EU AI Act Snapshot — two minutes, no signup. From there, SetAIComply covers the classification, bias testing, human-oversight records and Annex IV documentation an HR deployer or provider needs; see the plans (free tier included).