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Your HR AI tool is high-risk under the EU AI Act.

Any AI used in employment decisions is automatically high-risk under Annex III, point 4. That includes CV screening, candidate ranking, interview analysis, performance scoring, and redundancy selection. After the Digital Omnibus deal, you have until December 2, 2027 to comply.
See compliance plans
01 / High-risk

Which HR AI tools are high-risk?

If your product does any of the following, it falls under Annex III, point 4 (employment and worker management).

CV screening & candidate ranking

Any AI that filters, scores, or ranks job applicants based on CVs, cover letters, or application data.

Video interview analysis

Tools that analyse facial expressions, tone of voice, or word choice during interviews.

Performance scoring & reviews

AI that evaluates employee performance, recommends promotions, or flags underperformance.

Redundancy & termination decisions

Any AI involvement in selecting employees for redundancy, layoffs, or contract non-renewal.

02 / Your role

Building it or using it? Both have obligations.

The Act creates separate duties for providers who build AI and deployers who use it. If you buy HR AI software, you still have compliance work to do.

You build HR AI — provider

  • Full Annex IV technical documentation
  • Risk management system
  • Conformity assessment before market
  • EU database registration
  • Post-market monitoring

You use HR AI software — deployer

  • Implement human oversight as instructed
  • Monitor the system for anomalies
  • Keep logs for at least 6 months
  • Inform employees about the AI use
  • Run a data protection impact assessment
03 / Obligations

What high-risk HR AI must do

Every one of these must be in place before December 2, 2027. Non-compliance risks fines up to €15 million or 3% of global turnover.

  1. 01Risk management system (Article 9)
  2. 02Data governance & bias documentation (Article 10)
  3. 03Full Annex IV technical documentation
  4. 04Automatic event logging (Article 12)
  5. 05Transparency & instructions for deployers (Article 13)
  6. 06Human oversight measures (Article 14)
  7. 07Accuracy, robustness & cybersecurity (Article 15)
  8. 08Conformity assessment (Article 43)
  9. 09EU database registration (Article 49)
  10. 10Post-market monitoring (Article 72)
Further reading
7 min read

EU AI Act and HR Tools: What Employment AI Must Comply With

7 min read

EU AI Act for HR Software Buyers: What Deploying Workday, HireVue, or Any AI Hiring Tool Actually Requires

6 min read

Deployer vs Provider: What's the Difference and Why It Matters

Find out where your HR AI stands.

HR AI is one of the highest-scrutiny use cases under the Act. The classifier is free; classify your system and start generating the documentation you need.

Classify your AI system