Sample AI Compliance Report
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Company Context
Company
Acme Hiring Suite
Industry
HR & Recruitment
Company Size
51–250 employees
Risk Score
52/68
Executive Summary
Acme Hiring Suite is currently classified as High Risk due to AI-assisted candidate ranking and interview scoring workflows. The company uses three AI systems in production: a CV screening tool, an automated interview scorer, and a candidate ranking algorithm. The current governance posture shows partial controls in transparency and documentation, with material gaps in formal risk management and human oversight evidence.
Immediate priority should be implementing a documented risk-management process and a role-based oversight model before expanding AI use in employment decisions. Without these controls, the company faces potential fines of up to €35 million or 7% of global annual turnover under the EU AI Act.
Risk Classification
Acme Hiring Suite deploys AI systems that directly influence employment decisions — specifically candidate screening, interview scoring, and ranking. Under Annex III of the EU AI Act, AI systems used in recruitment and selection of candidates are explicitly classified as high-risk. The systems have a meaningful effect on individuals' access to employment, and the current lack of formal human oversight mechanisms increases the overall risk posture.
Compliance Gaps Identified
Risk Management System
HIGHNo formal risk management process exists for AI systems. Risk assessments are performed ad-hoc without documentation or periodic review cycles.
Implement a continuous risk management framework per Article 9 with documented risk identification, analysis, and mitigation measures.
Article 9, Article 17
Human Oversight Mechanisms
HIGHAI-generated candidate rankings are used directly without mandatory human review checkpoints. No override procedures are documented.
Establish mandatory human review for all adverse employment decisions. Document override authority and escalation procedures.
Article 14, Article 26
Technical Documentation
MEDIUMPartial documentation exists for the CV screening model but is missing for interview scoring and ranking systems. No Annex IV compliant documentation.
Create Annex IV compliant technical documentation for all three AI systems, including intended purpose, training data provenance, and performance metrics.
Article 11, Annex IV
Prioritized Action Plan
Appoint an AI compliance officer and establish governance committee
Timeline: Immediate (Week 1–2)
Implement Article 9 risk management framework with documented procedures
Timeline: Short-term (Month 1)
Add mandatory human review checkpoints before any adverse hiring decision
Timeline: Short-term (Month 1–2)
Create Annex IV technical documentation for all three AI systems
Timeline: Medium-term (Month 2–3)
Register high-risk AI systems in the EU database per Article 27
Timeline: Medium-term (Month 3)
Conduct initial Fundamental Rights Impact Assessment (FRIA)
Timeline: Medium-term (Month 3–4)
Implementation Timeline
Governance Setup
Appoint compliance owner, form governance committee, conduct internal AI system inventory, and establish communication protocols.
Critical Controls
Implement risk management framework, add human oversight checkpoints, begin technical documentation, and set up incident reporting.
Documentation & Registration
Complete Annex IV documentation for all systems, register in EU database, conduct FRIA, and establish monitoring dashboards.
Full Compliance
Complete all required conformity assessments, establish ongoing monitoring cadence, train staff on AI governance, and prepare for potential audits.
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