Are we a deployer if the AI came bundled in software we already bought?
Yes. You are a deployer of an AI system when you use it under your authority, whether or not you chose the feature. Recruitment screening, HR platforms and finance tools increasingly ship AI by default, and the Article 4 duty follows the use, not the purchase decision. If your team switches the feature on, or leaves it on, that is use.
Why HR is the sector to look at first
Recruitment and employment decisions are where AI features carry the most weight for the people on the receiving end, and some of them fall into the AI Act's high-risk category under Annex III, which lists AI intended to be used for the "recruitment or selection of natural persons". The Digital Omnibus moved the application date for those Annex III obligations to 2 December 2027, and under Article 111(2) a system already in service before that date is only brought in once its design changes significantly. Article 4 applies now regardless of risk tier. A ranking or filtering function that nobody on your team understands is the situation Article 4 exists to address.
Three questions to ask your HR platform
- Which features use AI, and for what decisions?
- What can we see about how a score or ranking was produced?
- What does the vendor say the human reviewer is meant to do with the output?
The answers go into your tool inventory. They also tell you who in HR needs role-calibrated depth rather than the baseline session.
What this means for training
The people who configure or rely on those features need to understand what the feature does, what it gets wrong, and what their own check adds. That is the difference between the half day and the full day.
Sources
- Regulation (EU) 2024/1689, the AI Act, Article 3(4) definition of deployer, Article 4, and Annex III point 4 on employment.
- Regulation (EU) 2026/1744, the Digital Omnibus on AI, for the deferred Annex III application date.
This is general information about the EU AI Act, not legal advice. Enforcement is proportionate and case by case, and your sectoral regulator may issue guidance that applies to you.
