Which AI use cases in professional services are high risk under the EU AI Act?

Annex III point 4(a) lists AI systems intended to be used for the recruitment or selection of natural persons, in particular to place targeted job advertisements, to analyze and filter job applications and to evaluate candidates. Screening, ranking and scoring applications is therefore high risk. A component limited to a narrow procedural task, such as booking interview slots or answering process questions, can fall outside the high risk category under Article 6(3), but only if it does not materially influence the outcome and does not profile people, and that assessment must be documented (Article 6(4)). Deployers of the high risk part must follow the instructions for use, assign competent human oversight, keep logs, inform workers' representatives and inform candidates that a high risk system is used (Article 26). An organization that builds its own screening system becomes its provider, with conformity assessment duties. The chatbot part also carries the Article 50 disclosure duty.

Research and drafting support for lawyers in firms and companies is not listed in Annex III, so it is normally minimal risk with AI literacy duties. Annex III point 8(a) makes it high risk when a judicial authority, or someone on its behalf, uses AI to research and interpret facts and the law and to apply the law to a concrete set of facts, or when it is used in a similar way in alternative dispute resolution, so a deployment for courts, tribunals or arbitration needs its own classification.

Decision support for professional investors and advisers about companies is not a use listed in Annex III and is not a practice prohibited by Article 5. The users are deal professionals who know they are working with an AI tool, and no consumer interacts with it, so the Article 50(1) duty to disclose an AI interaction has little practical effect. Article 50(2) is different: a firm that builds the assistant itself, including on a platform such as Blits.ai and putting it into service under its own name, is the provider of that system and must mark generated text in a machine readable format, unless the system only performs an assistive function for standard editing or does not substantially alter the input data or its semantics, which may cover extraction and redaction. A firm that instead licenses a vendor product, such as Datasite or Rogo, should confirm that the vendor meets this duty. Obligations are otherwise general: AI literacy for the deal team under Article 4 and, where personal data in the data room is processed, the GDPR.

Drafting outreach that a rep reviews and sends as their own message is typically minimal risk. If the agent holds conversations with prospects itself, for example by replying to emails or calling, people must be told they are interacting with AI (Article 50, limited risk). It is not an Annex III use case.

Triage of phishing, endpoint, network and cloud alerts for an organization's own cyber defense is not listed in Annex III. Recital 55 of the AI Act says that components intended to be used solely for cybersecurity purposes should not qualify as safety components, so the agent does not fall under Annex III point 2 (critical infrastructure), and for this scope the tier is minimal. The design changes that when the agent triages identity, data loss prevention, insider risk or user behavior alerts in a way that scores or monitors individual employees: monitoring and evaluating the behavior of persons in a work relationship falls under Annex III point 4(b), so that scope needs its own high risk assessment before it goes live. The Article 50(1) duty to disclose AI interaction does not apply because it is obvious to a reasonably well informed analyst that they are working with an AI agent. An operator that lets AI act autonomously on network or operational technology controls should assess that design separately, and reading employees' emails and sign in data remains subject to data protection law.

Answering onboarding questions and orchestrating provisioning is limited risk: under Article 50(1) the assistant must be designed so that employees are told they are interacting with AI, unless that is obvious. It becomes high risk under Annex III point 4(b) if it is used to make decisions on the terms or termination of the work relationship, to allocate tasks based on individual behavior or personal traits, or to monitor and evaluate new hires' performance or behavior, for example to judge probation.

Document review for a party in civil litigation or an internal investigation is not listed in Annex III, so it is usually minimal risk. It becomes high risk where a law enforcement authority uses AI to evaluate the reliability of evidence in the investigation or prosecution of criminal offenses (Annex III point 6(c)), or where a judicial authority uses it to research and interpret facts and law (point 8(a)). Prosecutors and investigators should classify each use against those points.

Translating and adapting commercial content is not an Annex III use and makes no decisions about people. When an organization uses a third party translation or generation tool, the use is minimal risk for the organization: the Article 50(2) duty to mark generated text in a machine readable way falls on the provider of that system, and beyond AI literacy no specific deployer obligations apply. When an organization builds and operates its own generating system and puts it into service under its own name, it is the provider and must mark the output, unless the exception for systems that only assist standard editing or do not substantially alter the input or its semantics applies. A faithful translation may fall within that exception; transcreation that rewrites the message for a market alters the semantics and is less likely to. Article 50(4) covers deepfakes and text published to inform the public on matters of public interest, not marketing translations. Consumer protection and advertising rules apply to the translated text as to the original.

Transcribing and summarizing meetings for the participants is minimal risk. It becomes high risk under Annex III point 4(b) if transcripts are analyzed to monitor or evaluate individual workers' performance or behavior, and inferring participants' emotions from their voices or faces at work is prohibited by Article 5(1)(f). Recording and transcription also need a lawful basis and clear information to participants under GDPR.

Drafting bid responses for staff to review is not listed in Annex III, and the buyer receives the seller's own document rather than interacting with an AI system, so the high risk tier and the Article 50(1) duty towards the buyer do not apply. Staff who chat with the agent must know it is an AI system, which an internal tool labeled as an AI assistant meets by design. Article 50(2) does apply to the drafting itself: the provider of a system that generates text must mark its output in a machine readable format as artificially generated, whether or not a person reviews the draft, unless the system only performs an assistive function for standard editing. A seller that uses a third party drafting tool relies on that tool's provider for the marking; a seller that builds its own agent that generates proposal text, as GroupeActive did with Witivio on Copilot Studio, can be the provider and then carries the duty itself. AI literacy under Article 4 applies in both cases, and the seller remains responsible for every statement in the submitted response.

A customer facing collections agent must disclose that it is AI (Article 50). It is not listed in Annex III as long as it applies preapproved arrangement rules and does not itself evaluate creditworthiness; an affordability model that decides who gets which arrangement for individuals should be assessed separately against Annex III point 5(b).

A treasury assistant interacts directly with staff, so Article 50(1) requires that they are informed they are dealing with an AI system unless that is obvious from the context. It is not listed in Annex III and makes no decision about a natural person.

Article 50(1) requires that people who interact directly with an AI system are informed of it, unless this is obvious from the context, as it usually is for an internal assistant. The system would be high risk only if it were intended for an Annex III purpose, such as assessing the creditworthiness of natural persons (point 5(b)) or making decisions on or evaluating workers (point 4(b)).

A coding assistant used by developers is not a prohibited practice under Article 5 and is not listed in Annex III. Developers know they are working with an AI tool, so the Article 50 disclosure duty has no practical effect for the deploying organization, and the marking of generated content under Article 50(2) falls on the tool's provider. What remains is AI literacy (Article 4). Using an AI system to monitor or evaluate individual developers' performance would fall under Annex III point 4(b), and the software the assistant helps build may itself fall under the Act.

Summarizing public threat reporting for an organization's own cyber defense is not an Annex III use, and recital 55 of the AI Act says components used solely for cybersecurity purposes do not qualify as safety components. The tier stays minimal while the assistant works on public sources and an analyst reviews and takes responsibility for what is published. It changes if the same tooling is used to profile or score employees.

Tracking contractual obligations and sending reminders is not among the Annex III high risk uses; an internal tool that extracts terms and alerts an owner makes no decision about a natural person's access to a service, employment or credit, so it is minimal risk under the EU AI Act, with the Article 4 duty to give staff who operate it appropriate AI literacy. The DORA and APRA CPS 230 entries below apply only when the deploying organization is itself a regulated bank, insurer or other financial entity; for other industries they do not apply.