The AI Act for recruitment agencies: your CV screener is high-risk
Recruitment is one of the AI Act's named high-risk domains. What agencies must do now, and what's deferred to December 2027.
Published by Kritia · legal snapshot reviewed 1 September 2026
Why recruiters are squarely in scope
AI systems used for recruitment or selection (CV screening, candidate ranking, interview analysis) are listed in Annex III as high-risk. The Digital Omnibus moved full high-risk duties to 2 December 2027, but the clock is running, and the general duties already apply now.
What applies today
Article 4: staff using AI screening tools need literacy measures and evidence, arguably more than any other sector, because your AI decisions affect people's livelihoods. Article 50: if candidates interact with a chatbot or receive AI-drafted communications on matters like rejections, disclosure duties can bite. And GDPR has always applied to automated candidate processing.
Preparing for December 2027
Inventory every AI feature in your ATS and sourcing stack. Ask each vendor for their AI Act conformity roadmap now. You have procurement leverage before the deadline, none after. Ensure a human meaningfully reviews AI-influenced decisions, and document that oversight.
Primary sources
The legal snapshot for this guide was checked against the documents below on 1 September 2026. Links go to the institution that published each source, not to a summary of it.
- Regulation (EU) 2024/1689 — Artificial Intelligence ActOfficial Journal of the European Union
- Regulation (EU) 2026/1744 — Digital Omnibus on AIOfficial Journal of the European Union
- Regulation (EU) 2016/679 — General Data Protection RegulationOfficial Journal of the European Union
When this guide goes out of date, you’ll hear it here
This page was last reviewed on 1 September 2026. The wording behind it has already moved once this year. Kritia Law Watch is a free daily email for firms that use AI tools rather than build them: one thing that matters, published decisions kept separate from proposals, every claim linked to the authority that published it. A minute to read.
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Compliance information, not legal advice. Basis: Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744, directly applicable in all EU member states; national implementing laws vary by country. Last reviewed 1 September 2026.