AI Act FAQ

AI in HR & Recruitment: Frequently Asked Questions

5 questions answered with specific EU AI Act article references. 0 days until Annex III high-risk obligations apply on 2 December 2027 (Digital Omnibus on AI, Regulation (EU) 2026/1744); Article 50 transparency obligations have applied since 2 August 2026.

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Is recruitment AI high-risk?

Yes. AI systems for recruitment, candidate screening, interview evaluation, and hiring decisions are explicitly high-risk under Annex III category 4(a).

What about internal HR AI?

AI for task allocation, performance monitoring, promotion decisions, and termination support are also high-risk under Annex III category 4(b-e).

What must employers do?

Non-discrimination testing, transparency to candidates (including that AI is used), human oversight of final decisions, documentation of how the AI works, and worker representative consultation where national law requires it.

Can AI screen CVs?

Yes, but as a high-risk system with full compliance. The AI must be tested for bias across protected characteristics, candidates must be informed, and a human must review flagged decisions.

Does emotion recognition in interviews violate the AI Act?

Yes. Emotion recognition AI in the workplace is a prohibited practice under Article 5(1)(f). This includes AI systems that analyse facial expressions or voice patterns during interviews.

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