Sector
AI literacy training for recruitment and HR.
Applicant tracking, screening and HR platforms increasingly rank, filter and score people by default. Article 4 asks you to take measures that help the people who use those features understand them, and Annex III of the AI Act puts several of them in the high-risk tier.
Where AI is already in the work
- CV screening and candidate ranking inside applicant tracking systems
- Targeted job advertising that decides who sees a vacancy
- Interview scheduling and video-interview scoring tools
- Performance, absence and productivity monitoring inside HR platforms
- Drafting job descriptions, offer letters and policies with a general-purpose chatbot
What the AI Act asks of you
Article 4 applies to every organisation whose staff use an AI system at work, and it has applied since 2 February 2025. Supervision and enforcement by national authorities started on 2 August 2026. The duty is to take measures that support the development of AI literacy among your staff and the people using AI on your behalf, calibrated to the tools in use, the people using them and the context. The Commission's Q&A is explicit that no certificate is required and that organisations can keep an internal record of training and guidance.
Annex III point 4 of the AI Act lists AI used for the recruitment or selection of natural persons, including targeted job advertisements, filtering applications and evaluating candidates, and AI used to make decisions affecting the terms of work-related relationships, promotion, termination, task allocation, or the monitoring and evaluation of performance and behaviour, as high-risk. The Digital Omnibus moved the application date for most Annex III obligations to 2 December 2027. Article 4 does not wait for that date.
Under Article 111(2), a high-risk system that was already in service before that date is only brought in once its design changes significantly.
When those high-risk obligations apply, Article 26 requires deployers to assign human oversight to people with the necessary competence, training and authority, and requires employers to inform workers' representatives and the affected workers before putting a high-risk system into service at the workplace. A recruiter who cannot explain how a ranking was produced is the gap both articles describe.
Which workshop fits
Most HR teams start with the half day for everyone who touches an AI feature, then the full day where the people who configure screening or monitoring tools need role-calibrated depth and a first acceptable-use policy.
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.
Questions from this sector.
Is our applicant tracking system a high-risk AI system?
If it uses AI to filter applications, evaluate candidates or target job advertisements, Annex III point 4 of the AI Act lists that use as high-risk. Whether a specific product qualifies depends on what the feature does, which is the first thing the tool inventory in our workshops establishes. The high-risk obligations on deployers apply from 2 December 2027, and a system already in service before then is brought in once its design changes significantly. Article 4 applies now.
We did not choose the AI in our HR software. Does Article 4 still apply?
Yes. You are a deployer of an AI system when you use it under your authority, whether or not you chose the feature. If your team switches the feature on, or leaves it on, that is use.
Do we have to tell staff we are using AI to monitor or evaluate them?
For high-risk systems, yes. Article 26(7) requires employers to inform workers' representatives and the affected workers that they will be subject to a high-risk AI system before putting it into service. Irish employment and data protection law may add duties of their own, which we flag but do not advise on.
Related insights.
Sectors
We did not choose the AI in our HR software. Are we still a deployer?
Yes. You are a deployer of an AI system when you use it under your authority, whether or not you chose the feature. The Article 4 duty follows the use, not the purchase decision.
Scope
Does Article 4 cover contractors and agencies working for us?
Yes. Article 4 covers people who deal with AI on your behalf whether or not they are on your payroll, so your measures should reach contractors, service providers and agencies too, in proportion to the systems they touch.