Classified examples · HR and employees · Po polsku
An AI tool screens and ranks job applications
High-risk (Annex III)Deployer
HR uses an applicant tracking system with AI that scores and ranks CVs against the job profile. Recruiters look at the top of the list first.
How we classify it
- The ATS vendor is the provider; the company deploys the system.
- Annex III point 4(a) lists AI systems intended to analyse and filter job applications and to evaluate candidates: high-risk.
- The Article 6(3) exception for narrow or preparatory tasks does not help: a system that profiles natural persons is always high-risk.
- Result: high-risk. The deployer obligations apply from 2 December 2027 (Digital Omnibus); GDPR applies now.
What applies now
- GDPR: inform candidates about the use of AI; no decision based solely on automated processing without the Article 22 safeguards
- A recruiter reviews every rejection with real authority to override
- Test for bias against groups of candidates and record the result
- Ask the vendor now whether the system will carry the CE marking and instructions for use by December 2027
What would change the answer
- From 2 December 2027: use according to instructions, trained human oversight, logs kept for at least six months, informing workers' representatives, informing candidates, and the right to an explanation (Articles 26 and 86)
Evidence to keep
- Classification record
- Impact assessment
- Vendor questionnaire
- Bias test results
- Candidate information notice
In the AI Compliance Kit: 04Risk Classification Procedure · 09AI Impact Assessment Template · 07Vendor Due Diligence Questionnaire · 03AI System Inventory · 06AI Literacy Programme.
Dates and sources
- High-risk obligations for stand-alone systems (Annex III): 2 December 2027
- AI literacy duty, Article 4: 2 February 2025
Legal basis: AI Act art. 6(3), 26, 86, Annex III point 4(a); GDPR art. 22.
Similar examples
- A video interview tool scores candidates' emotions Prohibited (Article 5)
- AI writes job ads, or decides who sees them Depends on the use
- AI monitors and scores employees' productivity High-risk (Annex III)