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AI Act and HR

2 min read
December 3, 2025
AI Act and HR

“The application of AI in HR is now, but not without challenges and concerns”

Technological advancements have brought various legal rules designed to regulate their use and protect individual rights. GDPR came into effect in 2018. In 2023, the European AI Act was approved. The AI Act has significant implications for HR organizations. Moreover, the topic is urgent because many HR organizations are already using AI unknowingly or will soon be using software with embedded AI as vendors incorporate AI into their solutions.

 

Introduction to the AI Act

In an era characterized by rapid technological progress, artificial intelligence (AI) stands at the forefront of innovation, promising transformative solutions. However, as AI integration becomes more pervasive, concerns about its ethical, legal, and societal implications have come to the fore. In response to these challenges, the European Union (EU) has introduced the AI Act.

The AI Act contains a set of rules and standards for the entire lifecycle of AI, from design and development to implementation and use.

Of particular importance is the application of the AI Act to Human Resources (HR). AI is already being applied across the entire HR value chain, and its use is likely to only increase.

However, the application of AI in HR is not without challenges and concerns. Issues related to bias, fairness, privacy, and discrimination have raised questions about the ethical and legal implications of AI-driven HR systems. The AI Act addresses these concerns by imposing strict requirements on AI applications in HR and ensuring they comply with the principles of fairness, non-discrimination, and data protection.

Why should HR organizations dedicate some of their precious time to the AI Act now?

As the AI Act is a binding law, AI is rapidly gaining popularity, and AI is already being applied, often without awareness, it is vital for HR organizations to allocate time and resources to familiarize themselves with the provisions of the AI Act.

By doing so, HR professionals can proactively assess the potential impact on their existing practices and develop strategies to seamlessly integrate the required changes. By staying ahead of developments and adapting in a timely manner, HR organizations can effectively mitigate potential risks and avoid penalties.

Moreover, by dedicating time to understanding the AI Act, HR organizations can enhance their ability to attract and retain top talent. In today’s competitive job market, candidates are increasingly concerned about the ethical use of AI in the workplace. By demonstrating compliance with the AI Act, HR organizations can build trust and credibility with employees and position themselves as preferred employers.

How to comply with the AI Act

Implementing the AI Act within HR organizations requires a comprehensive approach to evaluate existing processes, identify potential areas of non-compliance, and develop strategies for necessary adjustments.
The first step is to conduct a thorough audit of the HR systems and AI algorithms currently in use. This should at least meet the minimum requirements set out in the AI Act. Additionally, HR organizations should consider the ethical implications of AI in relation to their company values and potentially go beyond legal compliance.

Once the audit is completed, HR organizations can focus on implementing the necessary changes to ensure compliance with the AI Act.

Furthermore, organizations should establish mechanisms for continuous monitoring and evaluation to ensure they remain compliant with changing technology and regulations.

 

Finally, organizations should develop a process for introducing new, externally purchased or internally developed AI applications. Ideally, this process combines legal requirements from various perspectives, e.g., GDPR, AI Act, and labor law, as they interact with each other and because an integrated approach will save an enormous amount of time.

 

In conclusion, implementing the AI Act within HR organizations requires a multifaceted approach that goes beyond mere compliance. By conducting thorough audits and implementing necessary changes, HR professionals can ensure that AI technologies are used in a fair, transparent, and responsible manner.

How Highberg helps HR organizations become compliant with digital laws such as GDPR and AI Act

  • A 1-day training where participants are informed about the AI Act. Attention is paid to questions such as: What are AI use cases in HR, How is AI defined in the AI Act, What types of AI risk categories are distinguished, how do you determine which risk category an AI application falls into, and what actions need to be performed for each risk category? The training is a mix of theory and practice and is given by seasoned People Analytics and Digital Law experts.

  • Complying with the AI Act can be a daunting task and requires in-depth AI Act expertise. Highberg provides the frameworks, capacity, and in-depth expertise to manage AI Act implementation programs from A to Z.

  • With the introduction of the AI Act, conducting a DPIA is no longer sufficient in some cases. The AI Act relies on a mechanism similar to the DPIA in GDPR, the so-called Fundamental Rights Impact Assessment. Smart organizations integrate the DPIA and FRIA into a DPFIA. Highberg helps design the DPFIA process, the DPFIA framework, and assists clients in running AI use cases through the DPFIA framework to ensure compliance with the AI Act and GDPR.

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Other Highberg services related to the AI Act:

People Analytics Discovery Workshop

What is People Analytics? What are inspiring People Analytics use cases? Where to start building People Analytics muscles? What pitfalls should you avoid? Discover the answers to these and more questions in a vibrant workshop. Read more.

People Analytics Strategy

Increasing the chance of becoming data-driven, increasing the speed of transformation to data-driven, effectively removing People Analytics blockades, creating ROI from People Analytics. That’s the value of a solid People Analytics strategy. Read more.

People Analytics as a service

Wouldn’t it be great if you could rely on a partner to bring your organization to People Analytics maturity at lightning speed? Read more.

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