Recruitment edition
The major recruitment deadline has moved, but that is not a free pass: you remain jointly responsible for what your AI does to candidates.
Deadline for recruitment AI moves to December 2027, but your duty as a deployer starts now
What's new: the EU pushed enforcement back by 16 months, but the bans and the literacy requirement are already in force.
On 29 June 2026, the EU approved the Digital Omnibus package. This moves the enforcement deadline for high-risk recruitment AI from 2 August 2026 to 2 December 2027. CV screening, ranking candidates, and analysing video interviews remain 'high risk'. The delay is not a pause: banned practices and the duty to make your staff AI-literate apply now.
Background for subscribersThe deadline for high-risk recruitment AI moves to December 2027, but the bans and the AI literacy requirement apply now. If you use a tool for CV screening or candidate scoring, you are the deployer and you share the responsibility. That means acting now: understanding how your tool works, arranging human oversight, informing candidates, and documenting your decisions. With five LinkedIn Recruiter seats you can easily spend more than $40,000 a year, so it also makes financial sense to know exactly what you are buying and what the tool actually does.
You are the deployer: the builder is not the only one liable
The EU AI Act defines two roles: the provider builds the tool, the deployer puts it to use. If you use AI to screen CVs or score candidates, you are the deployer. You share the responsibility for fairness and transparency. Article 26 requires you to maintain human oversight, inform candidates, and follow your supplier's instructions.
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