Question 1

Does the EU AI Act apply to HR teams using AI tools?

Accepted Answer

Yes. HR teams that use AI for CV screening, candidate ranking, video interview scoring, or employee performance monitoring are deployers of high-risk AI systems under Annex III, Category 4 of the EU AI Act. Deployers have legal obligations including candidate disclosure, human oversight, and log retention from 2 August 2026.

Question 2

What must HR teams do to comply with the EU AI Act?

Accepted Answer

HR teams using high-risk AI must: (1) inform candidates in writing that AI was used in their assessment, (2) implement documented human oversight — a human must review AI output before decisions, (3) retain logs of AI system use for at least 6 months, (4) ensure AI literacy training for all staff who use the tools, (5) notify workers' representatives before deploying AI in employment contexts.

Question 3

Which HR AI tools are classified as high-risk under the EU AI Act?

Accepted Answer

AI tools used for recruitment are high-risk if they score, rank, or evaluate candidates. This includes HireVue, Pymetrics, LinkedIn Recruiter AI features, Workday AI hiring, Greenhouse AI, SAP SuccessFactors AI, and similar platforms. Tools used only for scheduling or calendar management without candidate evaluation are generally minimal risk.

Question 4

When does EU AI Act compliance apply to HR tools?

Accepted Answer

High-risk HR AI obligations apply from 2 August 2026 under current law. A provisional agreement (Digital Omnibus) proposes deferring this to 2 December 2027 but is not yet formally adopted. Candidate disclosure and worker notification should be implemented regardless of any deferral.

Question 5

Does the EU AI Act apply to US companies hiring EU employees?

Accepted Answer

Yes. The EU AI Act has extraterritorial reach. If a US company uses AI to assess candidates for positions in EU member states, the deployer obligations apply — regardless of where the company is headquartered. The determining factor is whether EU residents are affected by the AI system's output.

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