Industry guide
EU AI Act Compliance for HR & Recruitment AI
CV screening, candidate ranking, and employee performance monitoring are listed as high-risk in Annex III (duties from 2 December 2027). Emotion recognition in hiring or the workplace is already prohibited.
The EU AI Act classifies AI used in employment, workers management, and access to self-employment as high-risk (Annex III, point 4). This covers recruitment tools, promotion decisions, task allocation, performance monitoring, and termination support. Chapter III high-risk duties apply from 2 December 2027. Emotion recognition in the workplace or during recruitment is prohibited under Article 5(1)(f) and has applied since 2 February 2025.
Last updated: October 2026 · Regulation (EU) 2024/1689
High-risk use cases in this sector
- Automated CV screening and candidate ranking
- AI-driven interview analysis and scoring
- Employee performance monitoring and evaluation
- Workforce scheduling and task allocation AI
- Predictive attrition and promotion models
Key EU AI Act obligations
- Bias testing and fairness documentation (Article 10)
- Human oversight for employment decisions (Article 14)
- Transparency to candidates and employees (Article 13, 50)
- Fundamental rights impact assessment for deployers (Article 27)
- Registration in the EU database for high-risk systems (Article 49)
How Complee helps HR & Recruitment teams
If you use AI to rank candidates or monitor staff, Complee flags that as high-risk and opens the long questionnaire. Everyday tools like ChatGPT for writing job ads can use the standard compliance pack and Plus badge.
- Free assessment from your website and AI use description
- Compliance pack with inventory, literacy record, and transparency notice
- Plus subscription with a live badge and public verify page
Check your EU AI Act compliance
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