Human Oversight Protocol signed by M. Schmidt (CHRO)
5 days ago
β οΈ Employee transparency notice missing β Performance Monitor AI
1 week ago
Priority Actions 5 overdue
π΄
Issue employee transparency notice β Performance Monitor AI
Art. 13 Β· Immediate action required
π΄
Complete Bias Check β Performance Monitor AI (AIR fail)
Art. 9 & 10 Β· Due: 15 Jun 2026
π΄
Initiate DPIA for Performance Monitor AI
Art. 26(9) + GDPR Art. 35 Β· Overdue
π‘
Technical Documentation β Recruitment AI pending
Art. 11 Β· Due 15 Jun 2026
π‘
3 staff pending Article 4 certification
Art. 4 Β· Due 30 Jun 2026
EU AI Act β Key Deadlines
Feb 2025 β Prohibited AI practices banned
β Passed β compliant
Aug 2025 β GPAI rules & Art. 4 AI Literacy
β Partially met
Aug 2026 β High-Risk AI fully in scope
β 83 days remaining
Aug 2027 β All remaining provisions
Future
AI System Register
All AI systems used in your organisation β classified, documented, tracked.
π‘What is this & why do I need it?βΌ Show explanation
What it is: A complete list of every AI tool your company uses β from CV screening software to ChatGPT.
Why you need it: The EU AI Act requires every organisation to know exactly which AI systems they use and what they do. Without a register, you cannot prove compliance.
β οΈ Risk if missing: Regulators can fine you for not being able to demonstrate awareness of your own AI usage. This is the foundation of everything else.
β What to do: Think about every tool in your company that uses AI β HR software, chatbots, analytics tools, Microsoft Copilot, ChatGPT. Add each one here.
System Name
Department
Risk Level
Purpose
Annex III
Status
CV Screening AI HireVue GmbH Β· v2.1
HR / Recruitment
High Risk
Automated CV ranking & shortlisting
III Β· No.4
In Review
Performance Monitor AI Workday Analytics Β· v4.0
HR / People Ops
High Risk
Employee performance scoring & promotion
III Β· No.4
Action Needed
ChatGPT (HR Comms) OpenAI Β· GPT-4o
HR / Communications
Limited Risk
Drafting HR comms, job descriptions
N/A
Compliant
Scheduling Assistant Microsoft Copilot
Operations
Minimal Risk
Meeting scheduling, calendar optimisation
N/A
Compliant
Risk Classification
Classify each AI system under EU AI Act Article 6 and Annex III.
π‘What does "Risk Classification" mean for my company?βΌ Show explanation
What it means: The EU AI Act divides all AI systems into risk levels. The higher the risk, the more you must do to comply.
The 4 risk levels:
π΄ High Risk β AI used in HR, recruitment, performance, credit, education β strict rules apply
π‘ Limited Risk β Chatbots, content generators β transparency notices required
π’ Minimal Risk β Spam filters, scheduling β no specific obligations
β Prohibited β Social scoring, real-time biometric surveillance β completely banned
β οΈ Most HR software is High Risk β If your AI tool influences who gets hired, promoted, or fired, it is automatically High Risk under Annex III, No. 4.
β What to do: For each AI system, select its use case below. The system will automatically determine the correct risk level and tell you what you must do next.
Classify a System
β οΈ HIGH RISK β Annex III, No. 4
This system falls under EU AI Act Annex III No. 4 (Employment & HR management). Mandatory obligations: Technical Documentation, Human Oversight, Bias Monitoring, Conformity Assessment, Employee Notification (Art. 13).
See exactly what is done, what is missing, and what needs urgent attention.
π‘What is a Gap Analysis and why is it important?βΌ Show explanation
What it is: A Gap Analysis compares where you are today with where the law requires you to be. Each item on the checklist is a legal obligation.
Why it matters: This is usually the first thing a regulator or auditor will ask for β evidence that you systematically reviewed your compliance status.
β οΈ Fine risk: Red items are active compliance gaps. Each unresolved gap is a potential fine. The August 2026 deadline for High-Risk AI is approaching fast.
β What to do: Work through the red and yellow items first. Each item links to the relevant IADM training or service that can help you close the gap.
EU AI Act Compliance Checklist β Your High-Risk Systems
β
AI System Inventory documented
All 4 AI systems registered with use case and department
Art. 11 Β· Completed 01 Jun 2026
β
Risk classification completed for all systems
2 High Risk, 1 Limited, 1 Minimal β with written rationale
Art. 6 + Annex III Β· Completed 03 Jun 2026
β οΈ
Technical Documentation complete for all High-Risk systems
Completed for CV Screening AI β Performance Monitor AI pending
Art. 11 Β· Due 15 Jun 2026
π΄
Bias & fairness monitoring in place
AIR metric below threshold for Performance Monitor β remediation required
Art. 9 & 10 Β· Action required
β
Human Oversight Protocol signed and implemented
Protocol signed by CHRO M. Schmidt β override procedures documented
Art. 14 Β· Completed 05 Jun 2026
π΄
Affected individuals notified that AI is used
CV Screening: β done. Performance Monitor employees: NOT yet notified β HIGH FINE RISK
Art. 13 Β· Immediate action required
β οΈ
Vendor assessments completed for all AI providers
2 of 3 vendors responded β HireVue GmbH response outstanding
Art. 25 Β· Due 20 Jun 2026
β οΈ
Article 4 AI Literacy training for all relevant staff
8 of 11 staff certified β 3 pending
Art. 4 Β· Due 30 Jun 2026
π΄
Data Protection Impact Assessment (DPIA) completed
Required for High-Risk AI processing employee data β not yet initiated
Art. 26(9) + GDPR Art. 35 Β· Overdue
β οΈ
Incident reporting procedure established
No procedure in place for reporting AI-related incidents to authorities
Art. 26(5) Β· Due Aug 2026
β
AI Governance Policy published
HR AI Policy v1.2 published and communicated
Art. 9 Β· Completed 28 May 2026
Bias Check β Art. 9 & 10
Upload your HR data and get an instant bias report. No IT knowledge required.
π‘What is a Bias Check and why does the law require it?βΌ Show explanation
What it is: A Bias Check analyses whether your AI system treats different groups of people unfairly β for example, whether it selects fewer women than men for job interviews.
Why the law requires it: Articles 9 and 10 of the EU AI Act require that High-Risk AI systems are regularly tested for discriminatory outcomes. You must be able to show the results to regulators.
β οΈ Fine risk: If your AI discriminates β even unintentionally β and you cannot show you tested for it, you face fines up to β¬15M or 3% of annual turnover.
β What to do: Export a simple CSV from your HR system (just employee/applicant data with gender/age and outcomes). Upload it below. The system does the rest in seconds.
π EU AI Act Thresholds (Art. 9/10): AIR (Adverse Impact Ratio) β₯ 0.80 Β· DPD (Demographic Parity Difference) β€ 0.10 Β· EOD (Equal Opportunity Difference) β€ 0.10
Upload Your Data & Run Bias Check
π
Click to upload your CSV file
Export from your HR system: needs columns for protected attribute (e.g. Gender) + outcome (e.g. Hired: Yes/No)
βΉοΈ You can export this directly from most HR systems (SAP, Workday, BambooHR). You do NOT need to include names or personal identifiers β only the group attribute and the outcome.
β Overall Result: PASS β Your CV Screening AI meets EU AI Act fairness thresholds. Document this result in your Audit Evidence Folder.
Bias Check History
System
Date
Attribute
AIR
DPD
EOD
Result
CV Screening AI
Jun 2026
Gender
0.86
0.07
0.09
Pass
Performance Monitor
May 2026
Gender
0.74
0.12
0.11
Fail
CV Screening AI
Mar 2026
Gender
0.82
0.08
0.07
Pass
Governance & Oversight
Roles, policies, and human oversight β Art. 9 & 14.
π‘What does "Human Oversight" mean in practice?βΌ Show explanation
What it means: For every High-Risk AI system, a qualified human must be able to review, override, and if necessary switch off the AI. The law requires this to be formally documented.
In practice: Your HR manager who can override the CV screening result is your "Human Oversight Person." You need to write down who this is and what their authority covers.
β οΈ Risk: If an AI makes a bad decision (e.g. unfairly rejects a candidate) and you cannot show a human had oversight, you are fully liable under Art. 14.
β What to do: Assign a named person for each AI system. Document their authority to override the AI. Have it signed. Upload it here.
Governance Roles
Role
Person
Status
AI Compliance Officer
Dr. M. Schmidt
Assigned
Data Protection Officer
K. Weber
Assigned
AI System Owner β HR
S. MΓΌller
Assigned
Human Oversight Lead
T. Fischer
Assigned
CAIO / Executive Sponsor
Not assigned
Pending
Policy Documents
π
HR AI Policy v1.2Active
Published 28 May 2026 Β· Signed by CHRO
π
Human Oversight ProtocolSigned
Override procedures for all High-Risk systems
π
AI Incident Response PlanMissing
Not yet created β required under Art. 26(5)
π
Data Governance Policy (Art. 10)In Progress
Training data quality documentation
Vendor Assessment
Assess your AI providers' compliance β Art. 25.
π‘Why do I need to assess my AI vendors?βΌ Show explanation
What it means: When you buy or use an AI system from a vendor, you share compliance responsibility with them. You need to document that you asked your vendor the right questions.
In practice: You send a compliance enquiry to your AI vendor (e.g. HireVue, Workday) asking them to confirm their EU AI Act compliance status. Their written response becomes part of your audit evidence.
β οΈ Risk: If your vendor's AI is non-compliant and you never asked, you are also liable as the Deployer under Art. 25.
β What to do: Use the form below to generate a professional compliance enquiry letter. Send it to your vendor and upload their response here.
Vendor
System
Enquiry Sent
Response
Status
Workday Inc.
Performance Monitor AI
15 May 2026
β Received 22 May 2026
Complete
OpenAI / Microsoft
ChatGPT / Copilot
20 May 2026
β Received 28 May 2026
Complete
HireVue GmbH
CV Screening AI
01 Jun 2026
β No response yet
Overdue
Generate Vendor Compliance Enquiry
Article 4 β AI Literacy
Track and evidence AI literacy training for all relevant staff.
π‘What does Article 4 require from my company?βΌ Show explanation
What the law says: Article 4 of the EU AI Act requires that all employees who work with AI systems have "sufficient AI literacy" β meaning they understand what AI can and cannot do, and what the risks are.
What counts as "sufficient": There is no fixed standard, but completed AI literacy training from a recognised provider β like IADM's CPD-accredited programme β creates a strong, documentable record.
β οΈ Risk: If an AI causes harm and you cannot show that your staff were trained to use it responsibly, you face liability under Art. 4. This has been in force since August 2025.
β What to do: Add all staff who use AI tools. Enrol those who are not yet certified in an IADM AI Literacy training. Upload their certificates here as audit evidence.
Certified Staff
8
of 11 required
Pending Training
3
Due 30 Jun 2026
Training Provider
IADM Ltd
CPD Accredited Β· No. 021006
Staff Training Records Art. 4 Evidence Export Available
MS
Dr. M. Schmidt
CHRO Β· AI Compliance Officer
β Certified
IADM CAIO Β· 15 Apr 2026
KW
K. Weber
DPO
β Certified
IADM AI Literacy Β· 18 Apr 2026
SM
S. MΓΌller
HR Manager
β Certified
IADM AI Literacy Β· 20 Apr 2026
TF
T. Fischer
Recruiting Lead
β Certified
IADM AI Literacy Β· 22 Apr 2026
LB
L. Braun
HR Business Partner
β³ Pending
Due 30 Jun 2026
JK
J. Klein
People Analytics
β³ Pending
Due 30 Jun 2026
Transparency Obligations β Art. 13
Affected individuals must be informed when AI is used in decisions about them.
π‘What does Article 13 require β in simple terms?βΌ Show explanation
What it means: Every person who is affected by a High-Risk AI decision must be told β in clear language β that AI was used. For HR systems, this means:
β’ Job applicants must be told their CV was screened by AI
β’ Employees must be told their performance is monitored by AI
When to inform them: Before or at the time the AI makes a decision β not afterwards.
β οΈ This is one of the most commonly missed obligations. Not informing employees that AI monitors their performance is a direct and easily proven violation β and carries significant fine risk.
β What to do: Use the generator below to create the right notification text. It takes 2 minutes. Send it by email or add it to employment contracts.
β οΈ Action required: Employees using Performance Monitor AI have not yet been notified. This is a current compliance gap with direct fine risk. Generate and send the notice now.
Notification Status per System
β
CV Screening AI β Job Applicants Notified
Notice included in job postings & application confirmation emails since 01 May 2026
Art. 13(1) Β· Compliant
π΄
Performance Monitor AI β Employees NOT Yet Notified
No formal notification issued β immediate action required
Art. 13(1) Β· MISSING β HIGH FINE RISK
β
ChatGPT HR Comms β Transparency Notice Active
AI disclosure included in all HR communications footer
Art. 13(3) Β· Compliant
Generate Transparency Notice
Preview β Employee Notice
"We inform you that MΓΌller & Partner GmbH uses an AI-based performance management system (Workday Analytics) to support decisions related to your performance evaluation and potential promotion recommendations. All AI-assisted results are reviewed by a qualified HR manager before any final decision is made. You have the right to request a human review of any AI-assisted decision. Contact: hr-ai@muellerpartner.de"
Deployer Obligations β Art. 26
Your specific legal duties as the organisation using AI systems.
π‘What is a "Deployer" and what are my obligations?βΌ Show explanation
What "Deployer" means: You are a Deployer β a company that uses AI systems built by others (like Workday, HireVue, or OpenAI) in your own business context. This is different from the AI developer.
Why this matters: The EU AI Act gives Deployers their own set of obligations. You cannot simply say "the AI vendor is responsible." You have direct legal duties under Art. 26.
β οΈ Fine risk: Non-compliance with Art. 26 can result in fines up to β¬15M or 3% of global annual turnover. The DPIA requirement is especially often overlooked by KMUs.
β What to do: Work through the checklist below. Each red or yellow item is a gap you need to close before the August 2026 deadline.
Art. 26 Deployer Checklist
β
Use AI only within its intended purpose
All systems used within documented intended use case
Art. 26(1)
β
Assign a qualified responsible person
Dr. M. Schmidt assigned as AI Compliance Officer
Art. 26(1)
β
Implement human oversight as specified
Human Oversight Protocol signed and active
Art. 26(2) + Art. 14
β οΈ
Monitor AI system for risks during use
Bias monitoring active for CV Screening β Performance Monitor pending
Art. 26(5)
π΄
Establish incident reporting procedure
No procedure in place β define what counts as incident, who to notify
Art. 26(5) Β· Action required
β οΈ
Ensure staff have sufficient AI literacy
8 of 11 staff certified β 3 pending
Art. 26(6) + Art. 4
π΄
Conduct Data Protection Impact Assessment (DPIA)
Required for High-Risk AI processing employee data β not yet initiated
Art. 26(9) + GDPR Art. 35 Β· Overdue
β οΈ
Inform & consult employee representatives
Works council must be informed before deploying AI in HR
Art. 26(7) Β· Partially complete
Art. 26 Score & Priority Actions
50%
4 of 8 obligations met
β οΈ 2 critical gaps with highest fine risk: Incident reporting procedure missing + DPIA not initiated. Address these immediately.
1.
Create AI Incident Response Procedure
Who to notify, within what timeframe, how to document
Target: 20 Jun 2026
2.
Initiate DPIA for Performance Monitor AI
Engage DPO K. Weber β required before continued use
Target: 30 Jun 2026
3.
Notify employees about Performance Monitor AI
See Transparency module β Art. 13 notice required
Target: Immediately
Audit Evidence Folder
Your complete compliance evidence package β ready for any regulatory inspection.
π‘What is the Audit Evidence Folder?βΌ Show explanation
What it is: A structured collection of all the documents that prove your company complies with the EU AI Act. Think of it as your compliance passport.
When you need it: If a regulator, client, or auditor asks "can you prove you comply with the EU AI Act?" β you open this folder and show them.
β οΈ Without this folder, even if you are doing everything right, you cannot prove it. In regulatory terms, undocumented compliance is the same as non-compliance.
β What to do: Complete all 8 components. When all are green, click "Export Full Folder" to get a professional PDF package you can present to any auditor.