Your readiness summary

01 Executive summary

You have a clear view of where AI sits across the HR lifecycle. That puts you ahead of most teams at this stage.

Five of the eight areas use AI today; three are high risk under the EU AI Act. Emotion analysis in video interviews is prohibited and needs to come off this month.

The rest is procedural: a named reviewer for screening, a worker notice, and vendor documentation on file. None of these require a tool change. Starting now gives you time to sequence them well across the year.

02 Readiness across six capabilities

Act nowPrioritise nextOn trackEU AI Act tier is shown only on the AI uses.

Accountability
Act now
A named person can review and overrule each AI-influenced decision.
Transparency
Prioritise next
Candidates and employees are told when AI is shaping decisions about them.
Explainability
Prioritise next
You can explain the AI's role in a decision if asked.
Record-keeping
Prioritise next
Logs and oversight records are kept and exportable on request.
Vendor due diligence
Act now
Vendor roles, documentation, and ongoing assurance are in place.
AI literacy
On track
People using the tools have role-appropriate training.

Potential risks

Candidate Screening. Automated decision-making on people. High-risk under Annex III(4) and within scope of Art. 22 / Art. 86.
Interview Assessment. Inferring emotion from workers or candidates is banned in the workplace under Art. 5(1)(f). Stop the use now.
Performance Evaluation. AI narrows the field and rejected people are not meaningfully reviewed. That is a material-influence decision.

03 Act now

The top three to close first. Each item is a named deliverable with an owner and a date.

#	Gap	EU AI Act	Action	Owner · when
1	Stop emotion-recognition use in interview assessment	Art. 5(1)(f)	Disable the emotion or sentiment feature in interview assessment with the vendor and file the written confirmation in the HR evidence folder.	CHRO and Legal · this month
2	Stand up named human oversight for candidate screening, performance evaluation	Art. 14, 26(2)	Name a reviewer for candidate screening, performance evaluation who can overrule the AI, give them the inputs to do so, and log every override in a shared decision log.	HR ops lead · by month 1
3	Build accountability from scratch	Art. 14, Art. 26(2)	Publish a one-page oversight charter that names one accountable owner per high-risk system and the override they are authorised to make.	HR ops lead · by month 3

04 Prioritise next

The next three to build on once the top three are moving. Same shape: deliverable, owner, date.

#	Gap	EU AI Act	Action	Owner · when
1	Document oversight and review for candidate sourcing, monitoring and productivity	Art. 26	Replace informal sign-off on candidate sourcing, monitoring and productivity with a one-line written record per decision (who reviewed, what they saw, what they decided).	HR ops lead · by month 3
2	Close gaps in transparency	Art. 50	Add a standard AI-in-use line to candidate and employee communications at each touchpoint, agreed with Comms and Works Council.	Talent acquisition lead · by month 3
3	Close gaps in governance	Art. 86	Stand up an explanation-request workflow with a 10 working-day SLA and a templated response, published to managers and candidates.	HR ops and Legal · by month 4