What is the EU AI Act?

How the EU AI Act is defined

The EU AI Act, Regulation (EU) 2024/1689, sets harmonised rules for artificial intelligence across the European Union. It entered into force on August 1, 2024, and applies in stages. The AI Omnibus, Regulation (EU) 2026/1744, amended the Act and its timeline, and entered into force on July 27, 2026, according to the European Commission. This summary reflects the Act as amended and the Commission's published guidance as of November 11, 2026. This page is a general overview, not legal advice.

The Act sorts AI by risk. It bans a short list of practices, sets strict obligations for high-risk systems, and adds transparency rules for some other systems. It covers providers that place AI systems on the EU market and deployers that use them in the EU. Under Article 2, it also reaches providers and deployers outside the EU when the output of the system is used in the EU.

Annex III, point 4 lists two groups of high-risk systems in employment:

• Recruitment and selection: "AI systems intended to be used for the recruitment or selection of natural persons, in particular to place targeted job advertisements, to analyse and filter job applications, and to evaluate candidates."
• Decisions about workers: AI systems intended to make decisions affecting terms of work-related relationships, promotion, or termination, to allocate tasks based on individual behaviour or personal traits, or to monitor and evaluate the performance and behaviour of workers.

Under Article 6, paragraph 3, an Annex III system is not treated as high risk when it does not pose a significant risk of harm, for example when it performs a narrow procedural task or a preparatory task. A system that profiles people is always treated as high risk.

Key dates under Article 113, as amended:

• February 2, 2025: Prohibited practices and AI literacy rules began to apply. The prohibitions include AI that infers emotions in the workplace, except for medical or safety reasons.
• August 2, 2025: Rules for general-purpose AI models, governance, and penalties began to apply.
• August 2, 2026: The general date of application, including the transparency rules in Article 50.
• December 2, 2027: Rules for high-risk systems listed in Annex III, including employment, apply. The original date was August 2, 2026.
• August 2, 2028: Rules for high-risk AI built into products covered by Annex I apply.

Why the EU AI Act matters for talent teams

An employer that uses a high-risk system is a deployer. Article 26 requires deployers to use the system according to its instructions, assign human oversight to people with the necessary competence, training, and authority, and monitor how it operates. Where the deployer controls the input data, that data must be relevant and sufficiently representative for the system's purpose. Deployers must keep the logs the system generates, where those logs are under their control, for at least six months.

Article 26 also has rules specific to the workplace. Before putting a high-risk system into service at work, an employer must inform workers' representatives and the affected workers. People who are subject to decisions made with the help of an Annex III system must be told so. Under Article 86, a person affected by such a decision can ask the deployer for a clear and meaningful explanation of the AI system's role and the main elements of the decision.

The Commission's draft guidelines on high-risk classification, published on the AI Act Service Desk, give employment examples. Automated job matching and ranking tools, and systems that score applicants' answers in an assessment, are listed as high risk.

Fines are set in Article 99. Breaching the prohibited practices can lead to fines of up to EUR 35 million or 7% of worldwide annual turnover, whichever is higher. Breaching deployer obligations under Article 26 can lead to fines of up to EUR 15 million or 3%. Lower caps apply to smaller companies. Rules in the United States differ by state and city; see NYC Local Law 144 for one example.

How Findem approaches the EU AI Act

Findem is the People Intelligence Platform. Its AI does not reject candidates or make hiring decisions, and people review results before they influence hiring decisions. Read more in Responsible AI at Findem.

Findem's expert-labeled, evidence-backed signals are designed to provide explainability at every step, so a reviewer can see why someone was surfaced. No tool makes an employer compliant on its own. Whether the AI Act applies to a particular use, and in which role, is a question for each organization and its counsel.

Further reading

• AI governance in HR: A practical guide
• AI hiring laws in 2027: What Colorado, Connecticut, and California require