EU AI Act for Recruitment & Hiring: What HR Teams Must Do
AI is now embedded across hiring — CV screening, candidate ranking, video assessment and matching. Under the EU AI Act, most of these uses are classified as high risk, which means recruitment and HR teams carry real, enforceable obligations. Here's what applies and how to prepare.
Is it in scope?
The EU AI Act lists employment, workers management and access to self-employment as a high-risk area in Annex III. That explicitly covers AI used to recruit or select people — including tools that filter applications, rank candidates or evaluate them. If your candidates or output are in the EU, you are in scope even as a non-EU employer.
Typical AI use cases
- CV / resume screening and filtering
- Candidate ranking and shortlisting
- Automated video or game-based assessment
- Job-ad targeting and candidate matching
- Chatbots that pre-qualify applicants
Risk classification
Because recruitment falls under Annex III, these systems are high risk. Both the provider of the hiring tool and the deployer (the employer using it) have duties. Employers are usually deployers and must meet Article 26 obligations, including human oversight and informing affected candidates.
Obligations to prepare for
FAQ
Is CV screening software high-risk under the EU AI Act?
Yes. AI used to screen, filter or rank job applicants falls under the Annex III employment category and is classified as high-risk, triggering the full set of provider and deployer obligations.
Are employers responsible, or just the software vendor?
Both. The vendor is usually the provider and the employer is the deployer. Deployers have their own Article 26 duties, such as human oversight and informing affected candidates.
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