EU AI Act — Annex III, point 4 (recruitment and candidate screening)
High-risk obligations apply from 2 August 2026AI that screens CVs, ranks applicants, filters candidate pools, shortlists for human review, or determines whether a candidate advances is explicitly high-risk. Providers carry design, documentation and bias-testing duties; deployers owe human oversight, input-data quality, logging and candidate information. Penalties under Article 99 reach €15 million or 3% of global turnover.
What it means for the build: Per-decision logging, reproducibility and a documented human-oversight path become build requirements. A ranker that cannot reproduce a past decision cannot demonstrate compliance. Note that the Commission's November 2025 Digital Omnibus proposal may move this date, but it is not enacted law — building for the current date is the conservative call.