Annex III point 4High-risk domain

AI in employment and worker management

For organisations using AI in recruitment, selection, work terms, task allocation, monitoring or performance evaluation.

Annex III point 4 splits HR AI into recruitment/selection and worker management. The guidelines mention targeted job advertisements, filtering, candidate evaluation, terms of work, promotion, termination, task allocation, monitoring and performance evaluation.

Scope according to the guidelines

The HR route is already expanded in the theme pages for recruitment/selection and worker management/monitoring.

Classification question

Does the AI affect access to work, work terms, promotion, task allocation, monitoring or evaluation?

Read Article 6 classification rules Open Annex III legal text Use the Annex III classifier

What the Commission draft guidelines say

Summary by Praxikon of the draft of 19 May 2026. The draft is not binding; the final guidelines have not yet been published.

Point 4 covers the whole working life: targeted job ads, analysing and filtering applications and evaluating candidates (point a), and decisions on working conditions, promotion and termination, task allocation based on behaviour or traits and monitoring and evaluating performance (point b). According to the draft, what counts is whether the output meaningfully influences an opportunity, assessment or working condition; a recruiter making the final click does not change that. A system that assesses candidates or workers usually profiles them, and then the Article 6(3) exception falls away. Employers inform workers and their representatives before use (Article 26(7)). A FRIA applies to an employer only where it falls under Article 27, for example as a body governed by public law.

Examples that are high-risk

CV screening that ranks candidates on fit for a vacancy.
Analysis of video interviews, personality tests or game-based assessments.
Targeted job ads that use personal traits or behaviour to decide who sees the vacancy.
Rosters or work allocation based on individual profiles, and scores for promotion or reviews.

Examples that can fall outside

Interview scheduling and acknowledgements without assessing candidates.
Converting CVs into fixed fields without a score or ranking.
A chatbot answering practical questions about the procedure.
Anonymous productivity figures at team level.

Falling outside depends on the intended purpose and on the Article 6(3) exception, which never applies to profiling.

The overview of all eight areas and the dates is on Annex III of the AI Act; the Article 6(3) filter is explained in the Commission guidelines on high-risk AI.

Sources and status

This route is based on the Commission draft guidelines for high-risk classification, published on 19 May 2026. The examples are not exhaustive and may change when the guidance is finalised.

Always check Article 6 and Annex III of Regulation (EU) 2024/1689 as well. This page supports classification and evidence work, but it is not a supervisory decision.

Commission draft guidelines Official EU AI Act Article 6 on Praxikon Annex III on Praxikon 2026 guidance overview on Praxikon

High-risk obligations

If an AI system is high-risk under Annex III, classification and evidence should be linked to the relevant obligations for providers and deployers.

Article 9: Risk management system Article 10: Data and data governance Article 11: Technical documentation Article 12: Logging Article 13: Transparency and instructions for use Article 14: Human oversight Article 15: Accuracy, robustness and cybersecurity Article 26: Deployer obligations Article 27: FRIA where Article 27 applies

Use case guidance

Point 4(a)

Recruitment and selection

AI for targeted job advertisements, application filtering and candidate evaluation.

Point 4(b)

Worker management and work-related decisions

AI for work terms, promotion, termination, task allocation, monitoring or performance evaluation.

What to document

Intended purpose and context of use.

Why Article 6(2) and Annex III do or do not apply.

Whether the Article 6(3) filter may apply, and whether profiling blocks it.

Which provider and deployer obligations are triggered.

HR AI Risk & Evidence Sprint

Use the HR AI hub for route 4(a), route 4(b), checklist and evidence pack.

Start risk scan Schedule intake Expert page

Frequently asked questions

Short answers for classification, evidence and next steps under Annex III.

When should hr and work be assessed under Annex III?

The HR route is already expanded in the theme pages for recruitment/selection and worker management/monitoring. The practical starting question is: Does the AI affect access to work, work terms, promotion, task allocation, monitoring or evaluation?

Which use cases are included in Employment and worker management?

This domain page expands the main routes: Recruitment and selection and Worker management and work-related decisions. For each system, check the intended purpose, the output and the impact on access, rights or safety.

What should be documented before obligations are determined?

Document the intended purpose, use context, relevant Annex III route, Article 6(3) assessment, any profiling, provider/deployer roles and the required safeguards.