EU AI Act readiness for recruiting teams
Recruitment AI is classified as high-risk under Annex III of the EU AI Act. From 2 August 2026, every team using AI to screen, rank or evaluate candidates in the EU has to meet six concrete obligations. Here's the short version, plus a free PDF checklist you can hand to your DPO this afternoon.
The 6 obligations
- Obligation 1
Map your recruiting AI
Inventory every AI tool that touches a candidate. Screening, sourcing, video interviews, scoring, ranking. If it influences a hiring decision, it counts.
- Obligation 2
Run a fundamental rights impact assessment
Document the foreseeable impact of each tool on protected groups. Article 27 requires this before deployment.
- Obligation 3
Keep a human in the loop
No fully automated rejections. The Act requires meaningful human oversight on every consequential candidate decision.
- Obligation 4
Disclose AI to candidates
Candidates must be told, in plain language, when AI is used to evaluate them. Article 50.
- Obligation 5
Log decisions for auditability
Six months minimum of decision logs: which model, which inputs, which output, which human reviewed it.
- Obligation 6
Test for bias before and after deployment
Document the testing methodology, sample size, demographic groups covered, and remediation steps when bias is found.
How TenPerZent maps to the Act
- Defensible reasoning on every screening, exportable as a candidate-facing notice.
- Human approval required before any rejection email leaves the platform.
- Audit logs retained for 12 months, exportable in CSV or JSON.
- EU data residency with sub-processors listed in our DPA.
- Bias testing reports available on Business and Agency plans.
Frequently asked
- When does the EU AI Act apply to recruitment?
- High-risk obligations for AI systems used in employment, including recruitment, become enforceable on 2 August 2026. Prohibitions and AI literacy obligations are already in force.
- Does this apply to my company if we are not in the EU?
- Yes, if your AI system is used to evaluate candidates located in the EU, you fall in scope, regardless of where the provider or deployer is based.
- What's the penalty for non-compliance?
- Up to EUR 35M or 7% of global turnover, whichever is higher, for the most serious infringements. Article 99.
- How does TenPerZent help?
- Every screening on TenPerZent ships with a defensible reason, a human approval step, full audit logs, candidate-facing AI disclosures, and exportable bias reports.
- Is the checklist a substitute for legal advice?
- No. The checklist is a practical operational starting point. For binding compliance assessments, work with qualified counsel.