AI in Hiring — EU AI Act & Equality Law Compliance

AI systems used in recruitment, CV screening, candidate ranking, and hiring decisions are explicitly listed as High Risk under EU AI Act Annex III. This template covers the conformity requirements, equality law obligations, and GDPR Article 22 rights for job applicants.

Quick Answer

Recruitment AI is EU AI Act High Risk (Annex III). Conformity assessment, bias testing, human-in-the-loop for final decisions, and GDPR Article 22 disclosures are mandatory. Training data representing historical hiring can encode historical bias — this must be audited. UK businesses also face Equality Act 2010 indirect discrimination liability.

Compliance Checklist (8 items)

Classify your recruitment AI as High Risk under EU AI Act Annex III — conformity assessment is mandatory before deployment
Conduct an equality impact assessment — test AI outputs for differential impact across protected characteristics (sex, race, age, disability)
Do not make final hiring decisions automatically — human review of every AI-ranked candidate shortlist is required
Disclose to candidates that AI is used in screening — GDPR Article 22 requires disclosure of automated decision-making that significantly affects them
Provide a mechanism for candidates to request human review of an AI-generated rejection
Validate training data representativeness — ensure historical hiring data used to train the model does not encode historical bias
Maintain audit logs of AI screening decisions for three years minimum
Include AI use in job postings and application forms — candidates should know what data is collected and how it is used

Penalty if not compliant

EU AI Act High Risk violations: fines up to €30M or 6% of global turnover. GDPR Article 22 failures: up to €20M / 4% turnover. Equality Act 2010 discrimination claims in UK Employment Tribunal: unlimited compensation for indirect discrimination.

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