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The EU AI Act and Hello Recruiter
Prepared for the high-risk rules on December 2, 2027
The EU AI Act treats AI used to recruit, screen and evaluate candidates as high-risk, and those high-risk duties apply from December 2, 2027. Two rules already apply today: AI must not infer emotions at work, and people must be told when they’re talking to AI. Hello Recruiter, as the provider, meets both now and is building to the high-risk requirements; your company, as the deployer, has its own duties, set out below.
At a glance
- Law
- Regulation (EU) 2024/1689, as amended by the Digital Omnibus on AI, Regulation (EU) 2026/1744
- Applies to
- Providers and deployers of AI systems used in the EU, including non-EU companies whose AI output is used there
- Hiring AI
- High-risk (Annex III, employment)
- Already in force
- Ban on inferring emotions at work and AI literacy (since February 2, 2025); telling people they’re interacting with AI (since August 2, 2026)
- High-risk duties apply
- December 2, 2027 (moved from August 2, 2026 by the Digital Omnibus)
- Roles
- Hello Recruiter is the provider. Your company is the deployer.
- Enforced by
- Market surveillance authorities in each EU country
- Hello Recruiter status
- Prepared: meets the rules already in force and is designed to the high-risk requirements
- Last reviewed
- October 2026
What the law requires
Providers of high-risk AI must run a risk management system, govern training and test data (including checking for bias), keep technical documentation and logs, give deployers clear instructions for use, design for human oversight, and meet accuracy, robustness and cybersecurity standards. They also complete a conformity assessment and register the system in the EU database before placing it on the market.
Deployers must use the system according to its instructions, assign human oversight to people with the competence, training and authority to do it, and keep the system’s logs for at least six months. Before using high-risk AI at work, they inform workers’ representatives and affected workers. They tell candidates that high-risk AI is used in decisions about them, and they explain a decision when someone asks.
How Hello Recruiter helps you comply
| What the law requires | What Hello Recruiter does (provider) | What your team does (deployer) | Applies from |
|---|---|---|---|
| No AI that infers emotions at work | Scores only the content of resumes and interview transcripts. No analysis of facial expressions, voice, tone or emotion. | Don’t add tools that infer emotions. | February 2, 2025 |
| AI literacy | Trains its own staff on AI and its risks, and explains how scoring and human review work in our product docs. | Take measures to build AI literacy among recruiters who use Hello Recruiter. | February 2, 2025 |
| Tell people they’re interacting with AI | The AI interviewer tells candidates up front that it is AI. | Nothing extra. | August 2, 2026 |
| Risk management and bias checks | Independent bias audit across sex, race/ethnicity and nine more protected traits, and an internal re-test whenever the AI model changes. | Give job criteria that are relevant and related to the job. | December 2, 2027 |
| Documentation and instructions for use | Documents intended use, limits and human oversight in our AI Disclosure and product docs. | Use Hello Recruiter as documented. | December 2, 2027 |
| Logs | Logs every evaluation and review action. Records for non-US roles are kept 6 months by default, which you can extend. | Keep logs for at least six months. | December 2, 2027 |
| Human oversight | The Human Review Center routes every AI result to people, who see the evidence, can fully override the AI scores and make the decision. Integrity flags also go to a person. | Assign trained reviewers with authority to change outcomes. | December 2, 2027 |
| Accuracy, robustness and cybersecurity | SOC 2 Type I complete; SOC 2 Type II, ISO 27001 and independent penetration testing underway. | Nothing extra. | December 2, 2027 |
| Conformity assessment and EU registration | Will complete the conformity assessment and register the system in the EU database before December 2, 2027. | Check the system is registered before relying on it. | December 2, 2027 |
| Inform workers and candidates | Discloses AI use to every candidate. | Inform workers’ representatives before use, and tell candidates high-risk AI is used. | December 2, 2027 |
| Explaining decisions | Every score traces from evidence to signals to competencies against your criteria. | Explain decisions to candidates who ask. | December 2, 2027 |
The EU AI Act sits alongside the GDPR, which already limits decisions made solely by automated means. See how Hello Recruiter supports GDPR.
Common questions
Is AI used in hiring high-risk under the EU AI Act?
Yes. AI used to recruit or select people, including to screen applications and evaluate candidates, is listed as high-risk in Annex III of the Act.
When do the EU AI Act’s high-risk rules apply to hiring AI?
December 2, 2027. The Digital Omnibus on AI, in force since July 27, 2026, moved the date from August 2, 2026.
Does the EU AI Act apply to Hello Recruiter, a US company?
Yes, when Hello Recruiter is used to hire in the EU or its output is used there. Hello Recruiter is the provider and the employer using it is the deployer.
Does Hello Recruiter use emotion recognition?
No. Inferring emotions at work has been banned in the EU since February 2, 2025. Hello Recruiter scores only what candidates write and say.
Do we have to tell candidates they’re talking to an AI interviewer?
Yes, and Hello Recruiter does it for you. The AI interviewer tells candidates up front that it is AI.
See the audit paperwork
Our bias audit report, SOC 2 report and security policies are on the trust center.
Other AI hiring laws
- NYC Local Law 144Bias audit, public results and candidate notices
- CaliforniaFEHA automated-decision rules and CCPA ADMT
- IllinoisAI Video Interview Act and HB 3773
- Colorado AI ActNotices, adverse action and records from January 1, 2027
- GDPR and UK GDPRProcessor terms, transfers and human review
- All trust and complianceSecurity, privacy and AI hiring status in one place
This page explains how Hello Recruiter supports compliance. It is not legal advice. Your obligations depend on where you hire and how you use Hello Recruiter, so confirm them with your counsel. If this page differs from our legal documents, the documents govern.
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