Employment & worker management: is it high-risk under the EU AI Act?
AI for recruitment or selection (targeting, screening, evaluating candidates), and for decisions on terms, promotion, termination, task allocation, or monitoring and evaluating performance and behaviour.
Classification test
Falling in this domain is necessary but not sufficient. Under Article 6(2) the system is high-risk only if it also performs one of the specific functions the domain's text lists. A 'human in the loop' does not by itself remove high-risk status if the AI materially influences the decision; scope extends to platform and gig workers.
Example systems
- CV-screening and candidate-ranking tools
- Automated interview scoring
- Task-allocation and performance-monitoring systems (incl. gig/platform work)
If it is high-risk, these obligations apply
- Declare accuracy metrics in instructions for use — Provider
- Evidence robustness / resilience — Provider
- Evidence AI-specific cybersecurity — Provider
- Run a lifecycle risk-management system — Provider
- Govern training, validation and test data — Provider
- Assign human oversight and use per instructions (deployer) — Deployer
- Draw up & maintain the Annex IV technical file — Provider
- Classify the system against Article 6 / Annex III — Provider, Deployer
- Register in the EU database — Provider, Deployer
- Complete conformity assessment before market — Provider
All high-risk (Annex III) obligations → · How to classify under Article 6 →
Legal source
Annex III AIA · Commission draft HRAI guidelines, 19 May 2026
FAQ
Is employment & worker management AI high-risk under the EU AI Act?
It is high-risk under Article 6(2) if it matches the Annex III employment & worker management domain and performs a listed function. A 'human in the loop' does not by itself remove high-risk status if the AI materially influences the decision; scope extends to platform and gig workers.
What must I do if it is high-risk?
Run a risk-management system, govern your data, keep the Annex IV technical file, evidence accuracy/robustness/cybersecurity, complete conformity assessment and register in the EU database.
Stay audit-ready as the Act changes
EU AI Regulation Decoded tracks each obligation and the evidence auditors expect — one practitioner email a week.
Subscribe — free, weeklyNot legal advice. This is a practitioner reference generated from a cited knowledge base built on the primary legal text and official Commission guidance. Verify against the cited primary sources before relying on it for a compliance decision. See editorial standards & methodology.