AI adoption
The EU AI Act regulates AI according to risk. Certain uses in recruitment, employee assessment and task allocation fall within its high-risk categories. Following the AI Omnibus amendments, the rules for high-risk systems listed in Annex III apply from 2 December 2027. For high-risk AI embedded in regulated products covered by Annex I, the date is 2 August 2028.
Transparency requirements under Article 50 already apply from 2 August 2026. The 2 December 2026 deadline is a transition for certain providers of systems already on the market before 2 August 2026 to meet the marking and detection requirements of Article 50(2). It is not a general postponement of all transparency rules.
Our perspective
The revised timetable creates preparation time. Start by identifying AI uses that may be high-risk, including features introduced through HR software. Establish who owns each system, how people supervise it and what records are available. The applicable duties depend on the system, the company’s role and any transitional provisions; oversight, traceability and explanations are preparation priorities, not an exhaustive compliance checklist. Our recommendation: use the interval to build evidence and clarify responsibilities.
Sources
European Commission AI Act Service Desk — implementation timeline · European Commission — AI Omnibus enters into force · Regulation (EU) 2026/1744.
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