Industry — HR Technology
EU AI Act Annex III explicitly names hiring and HR management AI as high-risk. Here is what that means for your product.
If your product uses AI to rank candidates, assess employee performance, predict attrition, or inform promotion decisions and you have EU users, you are operating a high-risk AI system under the EU AI Act. Belto maps your specific obligations.
Conformity Assessment
High-risk AI systems must undergo conformity assessment before being placed on the EU market. This requires technical documentation, risk management records, and in some cases third-party audit.
EU AI Act — Article 43
Transparency Obligations
Individuals subject to AI-assisted hiring or HR decisions must be informed that AI is being used. The system's purpose, logic, and the individual's right to contest must be documented and accessible.
EU AI Act — Article 13
Human Oversight Requirement
High-risk AI systems must be designed to enable effective human oversight. Decisions cannot be fully delegated to automated systems without a documented human review mechanism.
EU AI Act — Article 14
Common Findings
What Belto identifies in HR AI compliance scans
No candidate transparency notice
AI-assisted hiring systems must inform candidates that AI is being used in the assessment process, the logic involved, and how to contest decisions. Most HR AI products deployed in the EU lack this disclosure.
EU AI Act Article 13 · GDPR Article 22
Missing human oversight mechanism
High-risk AI systems must be designed to allow effective human oversight. A manager reviewing an AI recommendation without the ability to override, query, or understand the logic does not constitute adequate oversight under Article 14.
EU AI Act Article 14
No conformity assessment on file
Before placing a high-risk HR AI system on the EU market, providers must complete a conformity assessment procedure. This requires technical documentation, testing records, and in some cases third-party audit.
EU AI Act Article 43
Algorithmic impact assessment absent
Canadian federal regulations require an algorithmic impact assessment before deploying automated decision systems affecting individuals. HR AI systems are explicitly in scope.
Canada ADM Directive · Section 6
Deadlines
Compliance timeline for HR AI operators
AI Literacy obligations active
Providers and deployers of all AI systems must ensure sufficient AI literacy for staff involved in operation and oversight. No grace period.
Annex III high-risk HR AI obligations
The deadline for full application of high-risk obligations under Annex III — including employment and HR systems — is December 2, 2027, per the Digital Omnibus timeline. Conformity assessments, technical documentation, and human oversight should be completed before that date. Article 4 (AI literacy) and Article 5 (prohibited practices) have been in force since February 2025.
Post-market monitoring
High-risk AI system operators must maintain continuous post-market monitoring. Performance tracking, incident reporting, and annual review obligations are active from the moment of deployment.
Belto maps your HR AI system against every applicable obligation.
From candidate ranking to performance assessment, Belto identifies exactly what your product needs before your EU customers ask.