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ARTICLE · 02 MARCH 2026

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Artificial Intelligence And Human Resources In The EU: A 2026 Legal Overview

Crowell & Moring LLP
Crowell & Moring LLP
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Crowell & Moring LLP

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Many AI tools deployed for HR purposes are likely to be classified as "high risk" under the AI Act, triggering strict obligations for employers, including mandatory human oversight...

European UnionTechnology

What You Need to Know

  • Key takeaway #1 Many AI tools deployed for HR purposes are likely to be classified as "high risk" under the AI Act, triggering strict obligations for employers, including mandatory human oversight and transparency requirements toward employees and their representatives. Full application of these obligations was initially scheduled for August 2026.
  • Key takeaway #2 The European Commission's Digital Omnibus package, currently under discussion, proposes to make the application of high-risk AI system obligations conditional on the availability of harmonized technical standards. In the absence of a Commission decision confirming such standards, the deadlines would be set no later than December 2027 or August 2028, depending on the classification of the high-risk system.

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