DepthThe conclusion and your first steps
Direct answer
We use AI in recruitment and selection. Is that high risk?
You describe: AI screening CVs, ranking candidates, targeting vacancies or analysing job interviews. Likely role: deployer (you use the system).
This applies now
- Article 4: AI literacyApplicable
- Article 50: transparencyApplicable
Coming up
- Annex III: high-risk AIfrom 2 December 2027
Recruitment falls under Annex III point 4. The core high-risk obligations apply from 2 December 2027, but classification, AI literacy and any transparency towards candidates matter today.
Your first actions
- Justify the Article 6(3) exception against each individual condition. Name which of the four Article 6(3) conditions you invoke, with facts, and separately justify why the system poses no significant risk of harm to health, safety or fundamental rights and does not materially influence the outcome of decision making.
- Take role- and context-specific AI literacy measures. Determine for each role, system and context which combination of instruction, guidance, practice or training is appropriate.
- Implement the applicable disclosure, marking or label. First determine which paragraph of Article 50 applies, then implement the specific transparency measure.
General interpretation, not legal advice. Checked against Regulation (EU) 2024/1689 and the Digital Omnibus (EU) 2026/1744; the official source remains authoritative.
Full map for your situation