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Your CV screening software might be high-risk. Here's how to tell.

Recruitment is one of the few areas where the EU AI Act names the use case directly.

If you're using software that shortlists, ranks, filters, or scores job applicants automatically, even a simple keyword-matching tool bolted onto your applicant tracking system, you're in one of the areas the EU AI Act specifically calls out. Annex III, the Act's own list of high-risk use cases, includes AI used to recruit or select people, covering advertising vacancies, screening applications, and evaluating candidates.

That doesn't mean the tool itself is banned or that you need to stop using it. High-risk under the Act means extra obligations, not a prohibition. You need a level of human oversight, someone reviewing and able to override what the system decides, a record of how it's being used, and staff who understand what it's actually doing, which is the AI literacy requirement that applies from August 2026.

Worth checking specifically: does the tool only surface information for a person to read, or does it make the actual shortlisting decision? A tool that ranks CVs by keyword match but leaves a human to make every call sits differently to one that auto-rejects candidates below a score. The more the software decides on its own, the more the high-risk obligations bite.

What this actually means for a small business

In practice, most small businesses aren't running anything close to the compliance overhead this sounds like. It's a short policy, a record of the tool and how it's used, and making sure whoever reviews CVs understands the AI's role in narrowing them down. Auley's checker will tell you in two minutes whether your setup counts, and generate that policy for you if it does.