Trazia · 2026
EU AI Act observatory for recruitment software
Research, regulatory analysis and implementation cases for teams building or buying AI recruitment technology. Every piece identifies its author, date and sources.
Latest analysis
- 02Article 4Which AI literacy measures can a company take besides a course?Article 4 calls for measures proportionate to knowledge, experience and context. Training can help, but it is neither the only format nor always the first step.August 29, 2026
4 min read - 03EvidenceWhat evidence should a company retain for its AI literacy measures?The Regulation prescribes neither a certificate nor a specific evidence file. A useful record links each use to the people, measure, date and reasoning behind it.August 28, 2026
4 min read - 04ObligationsAre AI literacy measures mandatory for companies in Spain?Yes, since 2 February 2025. But the Omnibus rewrote the article on 27 July 2026: it requires proportionate measures, not buying a particular course or guaranteeing each person’s level.August 25, 2026
5 min read - 05PracticeWhat AI training for your staff actually costs (and why the prices you see are not comparable)The Spanish market runs from €0 to nearly €17,000. The spread is not gouging: two different products are being sold under one name.August 25, 2026
4 min read - 06PracticeA client sends you an AI Act questionnaire: how to answer itA guide for the vendor, not the buyer. What these questionnaires ask, what you can answer today, what needs prior work, and three answers worth avoiding.August 25, 2026
6 min read - 07RegulationIs there a specific fine for failing to train staff on AI?Article 99 assigns Article 4 no dedicated EU penalty tier, but national authorities may sanction non-compliance. The duty is to take measures, not buy a particular course.August 25, 2026
5 min read - 08ResearchSpanish HR-tech under the microscope: 44 of 59 fall under Annex III, 45 never mention the AI ActOur own research across 59 HR-tech companies active in Spain and Europe. We measured what is published, not what is complied with — and the gap between the two is the story.August 5, 2026
6 min read - 09RegulationHow a financial regulator tests AI (and what your HR-tech learns from it)From 29 July 2026 BaFin can impose penalties. The way it tests AI systems previews the operational bar that procurement will eventually ask of you.August 3, 2026
5 min read - 10Prohibited practicesEmotion recognition at work is not ‘high-risk’: it is prohibitedThere is one case where hiring AI is neither classified nor documented: it is prohibited. Inferring emotions at work is a prohibited practice under Article 5, not a high-risk use.August 2, 2026
4 min read - 11SpainAESIA can now inspect and fine: what it looks for in an HR-techFrom 2 August 2026 the Spanish agency has full inspection and enforcement powers. It is worth understanding what starts now and what does not.August 1, 2026
5 min read - 12RegulationThe Omnibus moved 2 August to December 2027. Your procurement will not waitThe high-risk obligation deadline slipped by 16 months. The enterprise client's question did not move a single day.July 28, 2026
4 min read - 13ConformityWhy December 2027 is no breather: harmonised standards and presumption of conformityThe postponement did not come from a change of heart, but because the conformity standards were not ready. And a draft does not grant presumption of conformity.July 24, 2026
5 min read - 14ClassificationIs your matching or screening "high-risk"? How to read Annex III (employment)Annex III point 4 marks much of hiring AI as high-risk. The Article 6.3 exception is narrower than it looks.July 20, 2026
4 min read - 15ClassificationYou put your brand on OpenAI or Gemini: are you a provider? (Art. 25)Integrating a general-purpose model under your brand can make you a provider, with the heaviest obligations. "We just call the API" does not exempt you on its own.July 15, 2026
4 min read - 16Data protection‘Hired by an algorithm’: the AI Act does not free you from the GDPRThe EDPS and the EDPB put the spotlight on AI in hiring. The underlying reminder: over the same system the AI Act and the GDPR coexist, and one does not replace the other.July 11, 2026
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