Missing facts: 5 — Company role — provider vs deployer; Company establishment country / EU presence
Classification changes if: ranking is only preparatory and does not materially influence hiring, and the system does not profile natural persons (Art. 6(3)).
AI feature: "AI recruiting tool that analyzes candidate CVs and resumes, then ranks them by fit-score. Recruiters upload job descriptions and our AI model scores applicants automatically."
Not legal advice. This is a preliminary technical readiness scan. Findings include confidence levels, legal source trails, and missing facts — not a final classification, conformity assessment, or guarantee of compliance. Always consult a qualified lawyer.
Source: Art. 6(2), Annex III.4 Effective date: 2 December 2027 (standalone high-risk) Confidence: high Note: Ranking candidates for hiring typically materially influences selection — still confirm Art. 6(3) facts.
highEmployment / HR use-case signal (Annex III.4)
Source: Art. 6(2), Annex III.4 Effective date: 2 December 2027 Confidence: high Note: CV ranking / fit-score is an employment use-case signal.
highSensitive personal data processing — GDPR Art. 9 intersection
Source: GDPR Art. 9; AI Act Art. 10 if high-risk Effective date: GDPR already applies Confidence: medium Note: Separate GDPR analysis still required.
highFully automated decisions flagged — human oversight likely required
Source: AI Act human oversight; GDPR Art. 22 (if solely automated + significant effects) Effective date: GDPR Art. 22 already conditional; high-risk oversight from 2 Dec 2027 if Annex III applies Confidence: medium Note: Confirm whether a human can meaningfully override outcomes.
mediumUser-facing AI — Article 50 transparency likely relevant
Source: Art. 50 Effective date: 2 August 2026 Confidence: medium Note: Disclosure evidence is due now (in force 2 Aug 2026); Annex III employment duties remain 2 Dec 2027.
Annex IV technical file draft (if high-risk candidate)
Lawyer handoff brief
4. Facts to confirm before classification
Company role — provider vs deployer
Company establishment country / EU presence
Whether a human can reject or override the ranked shortlist
Who determines intended purpose — HireAI or the customer HR team
When the system was / will be placed on the EU market
5. Questions for counsel
Does our candidate ranking materially influence hiring decisions, or is it purely advisory (Art. 6(3) filter)?Are we a provider of the AI system or a deployer of a third-party model/tool?If Annex III.4 applies, when must registration and conformity documentation be ready given the 2 Dec 2027 standalone deadline?Is human review of AI recommendations sufficient, or do we need human-in-the-loop before any hiring action?What must be ready for Art. 50 (2 Aug 2026) vs Annex III duties (2 Dec 2027)?What documentation should we request from our model provider?
6. Recommended next steps
Treat this report as a preparatory brief for legal review — not a final classification
Legal status: In force now
Applicable from: Immediately
Source: Product methodology / disclaimer
Confidence: High
Confirm missing facts before locking any high-risk conclusion
Legal status: Requires legal confirmation
Applicable from: Immediately
Source: Art. 6(2)–(3) analysis prerequisites
Confidence: High
Draft / ship Article 50 transparency disclosures where applicable
Legal status: Upcoming — prepare now
Applicable from: 2 August 2026
Source: Art. 50
Confidence: High
Legal review of Annex III.4 applicability and Art. 6(3)
Legal status: Requires legal confirmation
Applicable from: Immediately (planning)
Source: Art. 6(2)–(3); Digital Omnibus timeline
Confidence: High
Start Annex IV technical-file outline if high-risk is confirmed
Legal status: Prepare now
Applicable from: 2 December 2027
Source: Art. 6(2), Annex III.4 / Annex IV
Confidence: High
Plan EU database registration only if provider of a confirmed high-risk system