Agentic Fluxus · Recruitment / performance / worker-management AI
HR AI 90-Day Compliance Plan
HR is the most under-prepared function for the EU AI Act. Recruitment AI, CV screening, performance scoring, promotion AI, gig allocation, and worker monitoring all sit in Annex III(4) high-risk territory. This 90-day plan sequences the compliance work.
13-week plan
| Week | Workstream | Deliverable |
|---|---|---|
| 1-2 | Inventory | Full HR AI inventory: every tool, every use case, every accountable owner. |
| 3-4 | Risk classification | Each tool mapped to Annex III(4) categories + Article 5 prohibitions check. |
| 5-6 | Article 5 audit | Confirm no emotion-recognition AI in workplace + no employee social-scoring AI. |
| 7-8 | Article 22 audit | Identify which decisions are solely-automated. Introduce meaningful human review OR confirm an Article 22(2) exemption. |
| 9-10 | Vendor contracts | Article 13 instructions for use + transparency notice + incident notification + audit cooperation in every contract. |
| 11 | Article 4 literacy | Train every staff member who touches HR AI. |
| 12 | Documentation | Article 11 + Annex IV technical documentation per system. Article 30 GDPR records updated. |
| 13 | Go-live + monitoring | Quarterly review schedule. Annual reassessment. Incident response procedure live. |
Article 5 prohibitions are live today
Article 5(1)(f) workplace emotion recognition + Article 5(1)(c) employee social scoring have been enforceable since 2 February 2025. Tier 1 fines (up to EUR 35M or 7%). Address this first.
Read the HR AI compliance guide:
https://agenticfluxus.com/blog/eu-ai-act-for-hr-teams
By John Ferguson · Founder, Agentic Fluxus · agenticfluxus.com · Amsterdam, Netherlands