Annex III names employment and worker management directly, including systems used to evaluate candidates.
Why it matters when the plan changes
Annex III is the list that decides whether a system carries the heavier set of obligations, and employment is on it explicitly, naming systems that place targeted job advertisements, filter applications and evaluate candidates. That makes classification a question to answer deliberately rather than a matter of opinion, and it makes documentation and oversight design questions to build toward now, ahead of the 2 December 2027 date when the obligations start applying, rather than things to assemble if someone asks.
The distance between building for the requirements and having met them is an assessment, and the two should not be described in the same words. A supplier that has built documentation, traceability and human oversight ahead of that date has done real work that can be shown. Whether the system meets the Act is a separate finding made against it, so the useful description of any system is what it does against each obligation, not a status word.
In practice
A procurement questionnaire asks whether a supplier is AI Act compliant. The answer that survives the next question names what the system does against each obligation: who reviews and signs the output, what a person can override, what is documented and who may see it, and which Annex III obligations apply to that use. A status word on its own, in either direction, does not.
Evidence
Annex III lists employment and worker management among the high-risk use cases, including systems that evaluate candidates.
Annex III, European Union Artificial Intelligence Act (2024)The obligations for systems classified as high risk under Annex III start applying from 2 December 2027.
Implementation timeline, European Union Artificial Intelligence Act (2024)
What it cannot tell you
Annex III determines which obligations apply; it does not itself specify how to meet them, and it does not certify that any particular system does. Classification is a starting point for assessment, not a verdict on a system's quality or fairness, and the Annex is silent on the substance of accuracy, bias testing or oversight design.
Questions
The use cases classified as high risk under the Act, grouped by area. Annex III, European Union Artificial Intelligence Act (2024), names employment, worker management and access to self-employment as one group, covering systems intended to place targeted job advertisements, filter applications and evaluate candidates.
Risk management, data governance, technical documentation, record keeping, transparency toward users, human oversight, and accuracy and security requirements, together with the conformity work needed to demonstrate them. The detail sits in the Act itself rather than in the Annex, which only establishes the classification.
The official implementation timeline gives 2 December 2027 for systems classified as high risk under Article 6(2) and Annex III. Dates in this area have been adjusted before, so the current official timeline is the source to check rather than a figure remembered from a briefing.
Atlas People does not state a compliance status either way, because that is settled by assessment against the Act rather than by a supplier's description. What is stated is the practice: a named consultant reviews and signs every report, no output decides anything about a person on its own, and documentation of the AI-assisted process is available on request.
No. It classifies certain uses as high risk and attaches obligations to them, chiefly around documentation, transparency and meaningful human oversight. The effect is to require that such systems be built and governed in a particular way, not to prohibit the category.