AI in Hiring is
High-Risk
CV screening, interview analysis, and performance monitoring AI are high-risk under Annex III. Here's what HR teams need to know.
Common HR AI Tools & Their Risk Level
| AI Tool | Risk Level | Why |
|---|---|---|
| CV/Resume Screening | High-Risk | Annex III.4(a) |
| Interview Scheduling AI | Minimal | Administrative only |
| Video Interview Analysis | High-Risk | Annex III.4(a) + emotion |
| Performance Monitoring | High-Risk | Annex III.4(b) |
| Shift Scheduling AI | Potential High-Risk | Annex III.4(b) |
| Chatbot for Candidate FAQs | Limited Risk | Art 50 disclosure |
Your Key Obligations
Use According to Instructions
Ensure AI tools are used per vendor documentation. Train recruiters on proper usage.
Human Oversight
All AI-assisted hiring decisions must have meaningful human review. Document who reviews and how.
Worker Notification
If using AI for existing employees, inform them and their representatives before deployment.
Transparency
Candidates should know when AI is being used in the hiring process.
Get Started
Inventory Your HR AI
Document all AI tools used in recruitment and HR processes.
Check Risk Levels
Confirm which tools are high-risk under Annex III.
Article 26 Checklist
Get your deployer obligations checklist for high-risk systems.
Frequently Asked Questions
Is CV screening AI high-risk under the EU AI Act?
Yes. AI systems used for recruitment or selection of candidates, including CV filtering and automated screening, are classified as high-risk under Annex III.4(a).
Do we need to tell candidates we use AI in hiring?
Yes. Under Article 26(7), if you use high-risk AI in employment contexts, you must inform workers. Additionally, Article 50 transparency requirements may apply for AI interactions.
What about AI interview tools?
AI used to assess candidates in interviews is high-risk. Video interview tools that analyze emotions or behaviour are particularly scrutinized and may trigger prohibited practices if not carefully deployed.
We just use AI for scheduling—is that high-risk?
Simple scheduling automation is typically not high-risk. However, if the AI influences who gets interviews or prioritizes candidates, it may fall under Annex III.4(a).
Get Your HR AI Compliant
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