Direct answer

We use AI to monitor or evaluate employees. What applies?

You describe: AI for task allocation, performance evaluation, promotion or termination decisions, or monitoring employee behaviour. Likely role: deployer (employer).

This applies now

Article 4: AI literacyApplicable

Coming up

Annex III: high-risk AIfrom 2 December 2027

Workforce management falls under Annex III point 4. Emotion recognition in the workplace is moreover a prohibited practice under Article 5, and that enforcement is already active.

Your first actions

Classify the use case and document the outcome. Assess Article 5, Article 6 and Annex III in that order and document purpose, context and any Article 6(3) exception.
Take role- and context-specific AI literacy measures. Determine for each role, system and context which combination of instruction, guidance, practice or training is appropriate.

Record this

Article 6 and Annex III classification record
AI literacy measures record

General interpretation, not legal advice. The official source remains authoritative.

Full map for your situation

Execution

Record the classification in an AI register

A classification without a register and ownership is not demonstrable. Embed AI guides classification, register and reassessment in a fixed approach.

See the Embed AI approach