EU AI Act analysis

Notes on the AI Act for HR techs using AI in hiring. Our own analysis, with the source linked. Not legal advice.

• Regulation·August 3, 2026·5 min read

  How 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.

• Prohibited practices·August 2, 2026·4 min read

  Emotion recognition at work is not ‘high-risk’: it is prohibited

  There 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.

• Spain·August 1, 2026·5 min read

  AESIA can now inspect and fine: what it looks for in an HR-tech

  From 2 August 2026 the Spanish agency has full inspection and enforcement powers. It is worth understanding what starts now and what does not.

• Regulation·July 28, 2026·4 min read

  The Omnibus moved 2 August to December 2027. Your procurement will not wait

  The high-risk obligation deadline slipped by 16 months. The enterprise client's question did not move a single day.

• Conformity·July 24, 2026·5 min read

  Why December 2027 is no breather: harmonised standards and presumption of conformity

  The 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.

• Classification·July 20, 2026·4 min read

  Is 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.

• Classification·July 15, 2026·4 min read

  You 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.

• Data protection·July 11, 2026·4 min read

  ‘Hired by an algorithm’: the AI Act does not free you from the GDPR

  The 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.