AI used in hiring is explicitly classified as high-risk under the EU AI Act.
EU AI Act Annex III places AI used in CV screening, candidate scoring, and interview assessment in the high-risk category. Equality Act obligations for protected characteristics in hiring decisions apply regardless of EU market exposure.
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The challenge
Common governance gaps for recruitment and hr organisations deploying AI.
Your screening tools are legally high-risk
CV screening, candidate ranking, and interview scoring tools are explicitly classified as high-risk under EU AI Act Annex III. Deployers must document compliance by 2 August 2026.
No bias testing evidence
ICO guidance requires organisations using AI in hiring to assess and document bias across protected characteristics. Most agencies using third-party tools have no evidence of this testing.
Article 22 transparency requirements
UK GDPR Article 22 requires candidates to be informed when significant decisions involve automated processing. Privacy notices and candidate-facing processes may need updating.
Regulatory obligations
EU AI Act Annex III, point 4 classifies AI used in targeted recruitment advertising, CV filtering, interview assessment, and worker performance evaluation as high-risk. ICO guidance on automated decision-making requires organisations to document how automated hiring tools are assessed for bias and how candidates are informed of automated processes under UK GDPR Article 22.
How AI Governance Hub helps
Platform features mapped to your specific governance workflow.
Risk Assessment with Bias Focus
A weighted assessment giving 1.2x weight to the Bias and Fairness category. Generates targeted mitigation actions for hiring AI including diverse test set recommendations and outcome monitoring.
AIIA Generator with Article 22 Support
Auto-generate impact assessments covering Article 22 automated decisions, necessity and proportionality tests, and candidate rights documentation.
Equality Act Compliance Checklist
Track your position against Equality Act 2010 obligations including protected characteristic impact assessment, indirect discrimination analysis, and reasonable adjustment evidence.
EU AI Act Dashboard
Track all 26 EU AI Act compliance items across 9 pillars for your recruitment AI systems. Know exactly what documentation gaps remain before the August 2026 deadline.
What you will have in 4 weeks
High-risk classification documented with EU AI Act Annex III evidence for every hiring tool
Bias assessment and mitigation record ready for ICO review or client audit
Article 22 candidate transparency documentation updated and stored
Important: AI Governance Hub is a preparation tool that helps you understand, document, and work towards your compliance requirements. It does not provide legal advice and does not certify regulatory compliance. You remain responsible for your own compliance obligations. Consult a qualified solicitor or data protection specialist for legal advice specific to your situation.
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