Regulation
NYC Local Law 144 and AI use cases
Bias audits and notices for automated employment decision tools used in hiring and promotion in New York City.
Read the source text (New York City)High risk under the EU AI Act
Listed in Annex III or a safety component: risk management, data governance, logging, human oversight and conformity assessment are required.
- AI agent for candidate sourcing and talent rediscovery
Annex III point 4(a) lists AI systems intended to be used to recruit or select natural persons, including to place targeted job advertisements and to analyse and filter applications. Ranking a company's own past applicants and new candidates against an open role, and deciding who a recruiter sees first, is filtering and evaluating candidates for that purpose.
- AI for recruitment screening and interview scheduling
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 analyse 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.
Depends on design under the EU AI Act
The tier depends on how the system is used, for example whether it decides on access to an essential service.
- AI internal talent marketplace for matching employees to projects, roles and mentors
Annex III point 4 lists AI used for the recruitment or selection of natural persons (4(a)) and AI used to make decisions affecting promotion, or to allocate tasks based on individual behaviour, personal traits or characteristics (4(b)). A marketplace that ranks employees for internal roles or allocates projects on the basis of inferred traits is therefore high risk. Recommending learning content or mentors to an employee who chooses freely is usually not. Deployers of the high risk part must inform workers' representatives and the affected employees before use (Article 26).