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AI in hiring is high-risk: EU AI act, deadline december 2026

Hiring AI is high-risk under the EU AI Act. Deployer duties, eight vendor questions and a 15-month plan to be ready for 2 December 2027.

If your company uses software to filter CVs, rank candidates or score video interviews, the EU AI Act already has a name for that software: high-risk. Annex III, point 4 of the regulation lists AI used in employment and worker management among the high-risk domains, next to credit scoring, education and law enforcement. That classification has not changed in 2026, and it will not change before the rules bite.

What changed is the date. The Digital Omnibus, in force since 27 July 2026, moved the compliance deadline for these stand-alone high-risk systems from 2 August 2026 to 2 December 2027. Sixteen months of breathing room, and a trap for anyone who reads it as a cancellation: HR software procurement cycles routinely run a year, and half of the compliance work (the inventory, the vendor answers, the worker information plan) has dependencies you do not control.