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EU AI ACT COMPLIANCE

HR Software Compliance Guides

Does your company use AI-powered HR software? As the business deploying these tools, you are the deployer under the EU AI Act — and deployer obligations are your responsibility, not the software vendor's. These guides explain exactly what you need to do for each tool.

Deadline: 2 August 2026. High-risk AI deployer obligations apply from this date. Most AI-powered recruitment tools are classified high-risk under Annex III Category 4. Action is required regardless of what your software vendor tells you.

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HireVue

HIGH RISK

AI video interview analysis triggers Annex III Category 4. Candidate disclosure, human oversight, and log retention required.

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Workday

HIGH RISK (some features)

Workday Recruiting and Skills Cloud are high-risk. HCM payroll and scheduling are not. Know which features apply.

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Greenhouse

HIGH RISK (AI features)

AI Scoring and Interview Intelligence are high-risk. Job posting and scheduling automation are not.

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LinkedIn Recruiter

HIGH RISK (AI recommendations)

AI Recommendations, Spotlights, and skills matching are high-risk. The upstream AI challenge explained.

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Intercom (Fin AI)

LIMITED RISK

Article 50 transparency disclosure required by 2 Aug 2026. Ready-to-use disclosure templates included.

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Non-EU Company Scope Checker

EXTRATERRITORIAL SCOPE

US, UK, or Indian company? 5 questions to determine whether the EU AI Act applies to you under Article 2(1)(c).

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SAP SuccessFactors

HIGH RISK (AI modules)

Recruiting AI, Opportunity Marketplace, and Workforce Analytics are high-risk. Enterprise deployer obligations explained.

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Lever ATS

HIGH RISK (AI features)

SMB-focused guide. Smart Recommendations and candidate scoring are high-risk. 5 steps for growing companies.

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Pymetrics / Harver

POSSIBLE BANNED PRACTICE

Emotion inference in the workplace prohibited since Feb 2025. Urgent legal review recommended for current users.

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Salesforce Einstein

CONTEXT-DEPENDENT

Risk depends on use case, not feature name. Sales scoring = low risk. HR or credit use cases = high risk.

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Oracle HCM Cloud

HIGH RISK (AI modules)

Recruiting AI, Dynamic Skills, and performance AI are high-risk. Dynamic Skills triggers worker notification for all EU employees.

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Microsoft Copilot

LIMITED / HIGH — by use case

Productivity use = Article 50 disclosure. HR decision use = high-risk. Same tool, different obligations by context.

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iCIMS Talent Cloud

HIGH RISK (AI Recruiting)

AI Recruiting and Skills-Based Hiring are high-risk. Digital Assistant chatbot needs Article 50 disclosure separately.

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SmartRecruiters

HIGH RISK (SmartAssistant AI)

SmartAssistant candidate matching is high-risk. GDPR compliance alone does not satisfy EU AI Act obligations.

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Bullhorn

HIGH RISK (staffing agency guide)

Staffing agencies using Bullhorn AI are the deployer — not the client employer. Obligations cannot be transferred downstream.

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Eightfold AI

HIGH RISK — deep inference

Eightfold infers career potential beyond stated skills. Explainability obligations intensify compared to simpler ATS tools.

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Paradox / Olivia

DUAL OBLIGATION

Olivia is both an Art.50 chatbot AND Annex III high-risk screening AI. Two separate compliance obligations apply.

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Zendesk AI

LIMITED RISK (standard use)

Answer Bot and messaging bots need Art.50 disclosure. Escalates to high-risk if used for credit, benefits, or HR decisions.

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Cornerstone OnDemand

HIGH RISK (talent & succession)

Succession planning and talent mobility AI are high-risk. Learning content recommendations are lower risk. Module-by-module guide.

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Beamery

HIGH RISK — talent CRM AI

Beamery assesses pipeline candidates passively before they apply. Disclosure must reach pipeline members, not just applicants.

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Oracle Taleo

HIGH RISK (Oracle AI features)

Legacy Taleo has limited AI. Oracle Recruiting Cloud AI features are high-risk. Check which modules are active before migrating.

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What do deployer obligations mean in practice?

When you use a third-party AI tool in HR, you are the deployer under the EU AI Act. This means:

The software vendor (HireVue, Workday, etc.) is the provider — they handle CE marking, Annex IV documentation, and EU registration of the system. You handle the deployment side.