AI systems used in employment decisions — including CV screening, candidate ranking, performance evaluation, and promotion decisions — are explicitly listed as high-risk in Annex III, point 4. Compliance is mandatory from August 2026.
Article 99 penalty for high-risk HR AI non-compliance
HR and recruitment AI that does not meet Articles 9–17 obligations by the deadline carries a penalty of up to €15,000,000 or 3% of global annual turnover, whichever is higher. Compliance is mandatory from 2 August 2026. GDPR Article 22 obligations (automated employment decisions) apply independently and in parallel.
Not sure if your hiring or evaluation tool is high-risk?
Describe what your system does and Regumatrix checks it against Annex III, Article 6, and the full regulation — in about 30 seconds. Your first 3 analyses are free.
Check my HR AI system — 3 free analyses includedArticle 22 of GDPR already restricts fully automated decisions in employment. The EU AI Act adds a separate layer: the AI system itself must meet high-risk requirements regardless of whether the final decision is automated or human-reviewed. Both regimes apply simultaneously.
Employment AI is one of the most-scrutinised Annex III categories. The line between a “matching tool” and a high-risk ranking system is where most teams underestimate their exposure. Check if any of these apply:
Employment AI is one of the most-scrutinised Annex III categories — regulators pay particular attention to bias, fairness, and automated decision-making in the workplace. Understand your exact exposure before August 2026.
Describe your AI system in plain language. Regumatrix checks it against every article of the EU AI Act and returns your risk tier, Annex classification, the exact obligations that apply, and your fine exposure under Article 99. Eight sections. About 30 seconds.
8-section report · Article citations · ~30 seconds · No credit card
