← Free risk checker
Home → HR Software Guides → Greenhouse EU AI Act
⚠ HIGH-RISK (AI features) — Annex III, Category 4

Greenhouse EU AI Act Compliance: Employer Guide 2026

Greenhouse is one of the most widely used ATSs in Europe. Its AI-powered candidate scoring and interview intelligence features are classified high-risk under the EU AI Act. Here is what your company must do as the deployer.

Key point: Standard Greenhouse ATS features (job posting, scheduling, offer letters) are not high-risk. But Greenhouse's AI candidate scoring, application filtering, and Interview Intelligence are. Check which features you have active — obligations only apply where AI evaluates people.

Which Greenhouse features are in scope?

FeatureEU AI Act statusReason
AI candidate scoring and rankingHIGH-RISKFilters and ranks applicants
Greenhouse Interview IntelligenceHIGH-RISKAI analysis of interview transcripts
Application filtering via AI fit scoreHIGH-RISKDetermines who advances in process
Job board posting and managementNOT high-riskNo AI evaluation of persons
Interview schedulingNOT high-riskLogistics only, no scoring
Offer management and onboardingNOT high-riskPost-decision workflow

Your deployer obligations

Need the templates? Get the HR Compliance Kit.

Candidate disclosure notice, worker notification letter, human oversight policy, and DPIA checklist — ready to adapt to your Greenhouse configuration.

Get HR Compliance Kit — €99 →
Or check your full risk level for free →

Greenhouse and the EU AI Act: full analysis

Greenhouse Interview Intelligence and the EU AI Act

Greenhouse Interview Intelligence records and transcribes interviews, then uses AI to surface themes, flag potential bias in questions, and help hiring managers compare candidates. Because this AI analysis influences who advances in the hiring process, it falls under Annex III Category 4 — AI used "to evaluate candidates in the course of interviews or tests."

Even if your recruiters treat the AI analysis as advisory rather than decisive, the system still falls in scope. The classification is based on the system's intended purpose, not how it is actually used in any individual case.

Candidate disclosure for Greenhouse users

Include a clear statement in your application confirmation email or job posting:

"We use AI-assisted tools to support our recruitment process. These tools may be used to analyse applications and interview performance. All AI assessments are reviewed by a member of our recruitment team before any decision is made. You may request information about how AI was used in reviewing your application by contacting [HR contact email]."

What to ask Greenhouse before the deadline

Contact your Greenhouse account manager and request:

Frequently asked questions

We use Greenhouse but have turned off the AI scoring feature. Do we still have obligations?
If you have disabled the AI candidate scoring and Interview Intelligence features and are using Greenhouse purely as a standard ATS (job posting, scheduling, offer management), you do not have high-risk AI Act obligations for Greenhouse specifically. Document that the AI features are disabled and keep that record. You still have the Article 4 AI literacy obligation for any staff using AI tools in their work.
Does Greenhouse itself have to comply, or do we?
Both. Greenhouse as the provider must complete conformity assessment, prepare Annex IV technical documentation, and register high-risk AI systems in the EU database. Your company as the deployer must implement human oversight, issue candidate disclosures, retain logs, train staff, and verify Greenhouse has met its obligations. If Greenhouse cannot produce a Declaration of Conformity by the enforcement date, you should disable the AI features or seek legal advice on your risk exposure.
We are a US startup using Greenhouse to hire remote EU-based engineers. Does this apply to us?
Yes. The EU AI Act applies wherever the AI system's output affects persons in the EU. If you are using Greenhouse AI scoring to assess candidates who are located in EU member states, you are a deployer under the Act, regardless of where your company is incorporated. This is one of the most commonly misunderstood aspects of the regulation for non-EU companies.