EU HR AI Risk Checklist

Put a governance structure around the AI behind your people decisions: a guide to what the EU AI Act treats as high-risk in HR, a classifier that flags high-risk, prohibited, or out-of-scope use, the deployer records, and a register that holds the whole inventory.

Four pieces that inventory and govern your HR AI

A guide to read, records you fill in per tool, a workbook that classifies and tracks, and a one-page orientation. Built to be used together across every tool you run.

• HR AI Risk Guide. What the AI Act treats as high-risk in HR, what it bans outright, the duties that fall on you as a deployer, the five risks to manage, and how to govern HR AI without a large team. A PDF to read first.
• Templates and Records. An inventory entry, a classification worksheet, a deployer checklist, a human oversight record, a notice checklist, a vendor questionnaire, and a decision record. A Word file to fill in per tool.
• HR AI Risk Workbook. An AI System Register, a Risk Classifier that flags each tool as high-risk, prohibited, or outside the list, a Readiness Tracker for the actions, and a definitions tab. It works in Excel or Google Sheets.
• Start Here. What each piece does and the order to use them. One page, read it first.

The method in the order governance runs

Classify first, inventory second, then the records and the readiness work. The checklist structures and documents the work; counsel and your data protection adviser handle anything near a banned practice.

• Classify each tool. Read the Guide, then run every tool through the Risk Classifier to see whether it is high-risk, prohibited, or outside the list, and how ready it is.
• Inventory it. Add every tool to the AI System Register so the whole inventory sits in one place.
• Document each one. Fill in the Records for each tool: the classification worksheet, the human oversight record, the notice checklist, and the vendor questionnaire.
• Work the readiness actions. Take the Readiness Tracker actions to done, set owners and due dates, and keep the evidence on file.

Who it is built for

Built for

• An HR or people team running recruitment, assessment, monitoring, or scheduling AI with workers in the EU, and no governance structure around it yet.
• A deployer that needs an inventory, a defensible classification, human-oversight and notice records, and a vendor questionnaire in one place.
• A team preparing for the high-risk obligations now, because the inventory, oversight, and records take months to stand up whatever the final date.

If you are looking for

• US multistate AI-in-hiring governance, not the EU Act. The AI Hiring and HR Governance Kit covers the bias-audit, notice, and oversight rules across US locations.
• One AI policy across the whole HR function. The AI in HR Policy and Risk Checklist covers AI use beyond hiring.

Before you buy

What format are the files and can I edit them?

One Guide PDF, one Word file of templates and records, one Excel workbook, and a Start Here PDF. The workbook works in Excel or Google Sheets, everything is editable, and the files are yours to keep.

What does the Act treat as high-risk in HR?

AI used in employment decisions: recruitment, candidate selection, performance evaluation, task allocation, worker monitoring, and decisions on promotion or termination. The Risk Classifier flags each tool as high-risk, prohibited, or outside the list.

The high-risk date moved. Why set up now?

The Digital Omnibus moving the high-risk obligations to 2 December 2027 was formally adopted in June 2026 and takes effect on publication in the Official Journal, expected before 2 August 2026. Either way, the inventory, oversight, and records take months to build, and the prohibited-practice and AI literacy duties already apply, so the work starts now.

Does the Act reach a company based outside the EU?

It applies where you operate in the EU or the output of your AI is used on people in the EU. If your hiring or monitoring touches EU-based workers, the deployer duties can reach you, so confirm your position with counsel.

Will it stay current as the rules settle?

This area moves, so each file shows its review date and meaningful updates are released as the timeline settles. Confirm the current status of the high-risk obligations before you rely on a date.

What is the refund policy?

Digital products are covered by a 14-day money-back guarantee. See the refund policy for the full terms.

What happens after I buy?

Checkout delivers an instant download link, and a receipt with the same link arrives by email. Open the Start Here page first; it tells you the order to work in. Questions or want a hand getting set up? Email support@truestephr.com.

How the download works

Your files arrive as a single ZIP download, best opened on a computer: save it, extract it (right-click and Extract All on Windows, double-click on a Mac), and open the Start Here file first. PDFs open in any reader, and the editable files work in Microsoft Word and Excel or their free equivalents, including LibreOffice and Google Docs and Sheets. No other software is needed. Step-by-step help for every device is at truestephr.com/pages/download-help.

Scope

This kit is a set of working tools and editable templates for running an HR process in a clear, consistent, and defensible way. It is not legal advice, and it is not a substitute for qualified counsel on your specific situation. The rules in this area vary by jurisdiction, they change, and applying a template to the wrong facts can create the exact exposure you are trying to avoid. Have your policies, your notices, and any individual decision reviewed against applicable law before you act on them.