Key facts

  • CV screening and candidate ranking AI is explicitly high-risk under Annex III.
  • AI influencing promotion, termination or task allocation decisions is also covered.
  • High-risk obligations apply regardless of company size, though proportionality provisions exist.
  • Human oversight of AI-influenced employment decisions is a core obligation.
  • HR teams should audit all AI-assisted recruitment and people-management tools now.

What counts as high-risk in HR and recruitment

Annex III explicitly covers AI used to place targeted job advertisements, screen or filter applications, evaluate candidates, and make or materially influence decisions on promotion, termination, task allocation based on individual behaviour or personal traits, or monitoring and evaluating performance.

Why this catches more tools than expected

Many HR teams use AI-assisted tools (CV parsing, candidate matching, performance analytics) without necessarily realising they fall within Annex III's employment category. An audit of every AI-assisted tool touching recruitment or people management is the essential first step.

Human oversight requirements

A core high-risk obligation is meaningful human oversight — a human must be able to understand, question and override AI-influenced employment decisions, not simply rubber-stamp an AI recommendation.

Practical next steps for HR teams

Inventory every AI tool used in recruitment and people management, classify each against the Annex III criteria, and build in genuine human oversight and documentation for any tool that qualifies as high-risk.

Frequently asked questions

Is recruitment AI high-risk under the EU AI Act?

Yes — AI used to screen, rank or evaluate job candidates is explicitly covered under Annex III.

What HR decisions beyond recruitment are covered?

AI materially influencing promotion, termination, task allocation or performance monitoring decisions.

Do small businesses get an exemption from HR AI obligations?

There are proportionality provisions for SMEs, but the underlying obligations still apply based on the AI's use case, not company size alone.

What is the human oversight requirement for HR AI?

A human must be able to understand, question and override AI-influenced employment decisions, not just approve them automatically.

What should HR teams do first?

Audit every AI tool used in recruitment and people management, and classify each against the Annex III criteria.

Related pages

Sources

Last updated 19 June 2026.