Why Take Action Now?
The AI Act has major impact on HR processes
August 2025
First obligations for high-risk AI systems come into effect
HR AI = High-risk
AI for recruitment and selection automatically falls under strictest rules
Discrimination Risk
Bias in HR-AI can lead to systematic discrimination and reputation damage
Employee Rights
Applicants and employees have right to transparency and explanation
High-risk AI in HR & Employment
These AI applications fall under strict AI Act requirements (Annex III)
Recruitment & Selection
AI systems that screen CVs, rank candidates or analyze interview results.
Performance Management
Systems that assess employee performance or provide development advice.
Compensation & Benefits
AI determining salaries, calculating bonuses or personalizing benefits.
Workforce Planning
Predictive models for workforce needs, turnover or capacity planning.
Specific Challenges for HR Organizations
The AI Act brings unique compliance questions for the HR sector
Bias Detection & Testing
How to test AI systems for direct and indirect discrimination? Which protected groups to monitor?
Transparency to Applicants
Applicants must know AI is being used. What to tell, and when?
GDPR & AI Act Integration
HR data is particularly sensitive. How to combine privacy compliance with AI Act?
External Tool Vendors
Much HR-AI comes from vendors like HireVue, Pymetrics, etc. What guarantees to request?
Human Oversight in Decisions
Recruiters must remain involved. How to prevent rubber-stamping?
Works Council & Co-determination
AI implementation often requires works council consent. How to involve them effectively?
AI Act Compliance Roadmap
Practical steps for HR organizations
HR-AI Inventory
1-2 weeksMap all AI systems in HR processes. From ATS to performance tools.
Impact Assessment
2-3 weeksDetermine per system the risk of discrimination and impact on employee rights.
Bias Audit
4-8 weeksTest AI systems for unwanted bias in outcomes for protected groups.
Process Redesign
2-4 monthsImplement human oversight and transparency measures in HR processes.
Monitoring & Reporting
OngoingSet up ongoing monitoring for bias and fairness metrics.
What Makes HR-AI Different?
Sector-specific considerations
Direct Impact on Life Course
HR decisions determine careers, income and quality of life
Historical Bias in Data
Training data often reflects existing inequalities in the labor market
Weak Position of Applicants
Applicants often do not dare to complain about AI use in recruitment
Works Council Rights
Personnel monitoring systems require works council co-determination