The EU AI Act will be fully enforced from December 2, 2027, and recruitment is officially classified as a high-risk area. But what does that mean for organizations already using AI in hiring, or planning to expand their RecTech stack?
The EU AI Act introduces strict requirements around transparency, data quality, and human oversight. For employers and TA teams, this means AI in recruitment can no longer operate as a black box.
So how can organizations continue using AI efficiently while staying compliant, ethical, and trusted by candidates?
According to the EU AI Act, any AI system influencing access to employment, education or financial opportunities falls under the high-risk category.
That means tools used to screen CVs, rank candidates or support hiring decisions must comply with eight key requirements.
One of the most important is human oversight. AI must never make decisions independently without human involvement. Recruiters and TA professionals must always be able to understand, question and override AI-generated outcomes. And all data must be explainable, so-called explainable AI.
Another critical requirement is data quality and bias control. Training data and scoring logic must be representative, fair and continuously monitored to avoid discriminatory outcomes related to gender, age, ethnicity or background.
The law also requires full transparency. Candidates have the right to know when and how AI is being used during the recruitment process.
In addition, organizations must ensure:
So what does this mean in reality? To better understand the regulation, it is easiest to explain the difference between compliant and non-compliant AI usage in recruitment, according to the EU AI Act guidelines.
Allowed under the AI Act
Not allowed under the AI Act
In short: AI can support recruiters, but it cannot replace human judgement.
Tengai was designed with compliance at its core. The platform is built around the requirements defined for high-risk AI systems while taking a fundamentally different approach to AI in recruitment. AI is not used to assess candidates. Instead, it is used to create a more engaged and consistent interview experience.
Risk-aware by design
Tengai relies on documented processes and static scoring frameworks, ensuring the system is not influenced by gender, ethnicity or other irrelevant factors.
Humans always make the decisions
Recruiters remain fully responsible for all hiring decisions. Tengai supports the process without replacing human judgement, reducing automation bias and helping ensure equal treatment of candidates.
Transparency from the start
Candidates are informed at the beginning of the interview that Tengai's AI avatar is used to power the interview experience and interface, not to evaluate performance, skills or any other type of assessment.
Want to ensure your recruitment technology is ready for the EU AI Act?
Contact our team to discover how you can future-proof your AI usage in recruitment while meeting the growing demands for transparency, fairness and human oversight.