The EU AI Act is the first EU law to categorize AI according to risk class. All tools that prepare hiring or promotion decisions are considered high-risk and must meet strict requirements on transparency, bias control and human oversight from 2025/26.
Contents
Why the EU AI Act is changing recruiting
High fines: Violations can cost up to € 35 million or 7% of global annual turnover* .
Recruiting = high-risk category: life-changing decisions (hiring, rejection, promotion) are particularly regulated*.
Extraterritorial effect: Non-EU companies are also affected if their tools evaluate applicants in the EU.
Schedule & deadlines
| Date | Milestone |
|---|---|
| July 12, 2024 | Publication in the EU Official Journal |
| 01 Aug 2024 | Formal entry into force |
| Aug 2025 | First obligations for basic models (e.g. GPT class) |
| Feb 2026 | Mandatoryhigh-risk obligations for recruiting tools |
| Aug 2026 | Full application & fine regime |
High-risk classification & prohibited HR use cases
| Permitted | High-risk (strictly regulated) | Prohibited |
|---|---|---|
| Chatbots that only inform | CV matching, ranking, video scoring, AI-based pre-screenings | Emotion recognition for suitability assessment, social scoring |
Note: As soon as a tool automatically decides “suitable/unsuitable”, it falls into the high-risk area. Emotion tracking or social scoring are prohibited as a matter of principle.
Your 7 mandatory building blocks (checklist)
Create AI tool inventory (purpose, data types, provider).
Check risk analysis & CE verification of each tool.
Data governance: Test training data for representativeness & bias.
Transparency: Clearly inform applicants that AI will be used – including fairness justification.
Defining human supervision: Who gets to adjust or stop AI decisions?
Logging & Incident Plan: Store results for at least five years; report serious incidents within 15 days.
Training & annual audit: bias awareness, tool competence, update compliance report.
Free AI Act compliance checklist
PDF (2 pages) – 14 tasks + responsibility matrix.
Download now and simply tick off: EU AI Act checklist free of charge
Download now and simply tick off: What the EU AI Act actually means for recruiting software – what does a bias audit involve?
Why recruiting tools are classified as high-risk AI
Annex III of the EU AI Act explicitly classifies AI systems in the areas of“recruitment, promotion or dismissal of persons” and “assessment of candidates” as high risk. This means that ATS matching algorithms, automated CV parsers and video assessments fall under the strictest obligations of the law Artificial Intelligence Act EU.
Binding requirements on risk management, data governance, transparency, technical documentation and human oversight will apply to high-risk systems from entry into force (2 Aug 2026) (Chapter III, Art. 9-15) futurium.ec.europa.eu.
Violations are punishable by fines of up to €35 million or 7% of global turnover Taylor Wessing Reuters.
What exactly does the bias audit according to Art. 10 require?
Article 10 obliges providers and operators to systematically check and document their training, validation and test datasets for bias and discrimination risks Artificial Intelligence Act – EUScienceDirect.
| Audit module | Brief description | Typical evidence |
|---|---|---|
| Data mapping | Disclose origin, representativeness & completeness of all training/evaluation data | Data sheet, schema diagram |
| Bias screening | Statistical checks for under/over-representation (e.g. gender, age, ethnicity) | Demographic report, p-value tests |
| Mitigation plan | Measures to correct identified biases (re-sampling, re-weighting, fairness constraints) | Versioned Jupyter notebooks / audit log |
| Performance & Fairness KPI | Documentation of Accuracy, F1 and Fairness metrics (e.g. Equal Opportunity Diff.) | Benchmark table |
| Continuous Monitoring | Post-market plan for drift detection & annual re-audits | Monitoring dashboard, ticket log |
Practical tip: Art. 10(5) even allows the processing of sensitive data (“special categories”) exclusively for bias correction, provided that strict protective measures are in place *Computer Law & Security Review: The International Journal of Technology Law and Practice.
Summarized: Why the EU AI Act is changing recruiting
Practical case: how Kooku conducted a pilot audit in only 28 days has carried out
Company: German medium-sized company (logistics, 750 employees)
Initial situation: ATS with automatic ranking & video scoring
Roadmap:
Day 1-5 inventory + bias test
Day 6-10 Obtain CE certificates
Day 11-15 Transparency texts in job advertisements
Day 16-24 Oversight workflow + logging
Day 25-28 Training & final audit
Result: Audit report fulfills AI Act obligations; additional -18% time-to-hire thanks to clear oversight paths.
Next steps with Kooku – your professional recruiting consultant
Needs-Assessment (30 min) – free quick check of your recruiting processes for possible weaknesses.
As required: AI-Act pilot audit – 4-week program incl. bias test & oversight setup.
As required: Data-driven recruiting – KPI dashboard & automation roadmap. Find out more about our consulting services now!
Zum Service: Recruiting Beratung von Kooku
Mit unseren Best Practices können Sie sich und Ihrem Recruiting-Team mittel- und langfristig bis zu 60 % administrativen Aufwand sparen und somit vollen Fokus auf das Wesentliche legen: Die nachhaltige Rekrutierung von Fach- und Führungskräften.
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