We only “assist” the recruiter. Are we out of Annex III?

Annex III covers systems intended to be used for those employment purposes, including analysing and filtering applications. “Assist” is not a statutory off-switch. Read the official Annex III wording for the exact system you sell.

Does AB 2013 apply to a hiring ranker?

Only if the ranker is a generative AI system or service under § 3110(c). A classifier that never generates synthetic content is outside AB 2013 and may still be inside Annex III and SB26-189.

AI hiring tools: EU high-risk duties and Colorado SB26-189 notices

A hiring ranker is the feature that jumps from “put a disclosure on it” to “you may have a high-risk AI system and, in Colorado, a covered ADMT.” Article 50 still applies if the tool chats with a candidate. It is not the main duty.

Educational resource only — not legal advice. scm.cc publishes a readiness report and engineering gap analysis for AI features. It does not give legal advice, represent you before a regulator, or state that a product is ready to ship under any law. This page is educational product guidance, not legal advice. It is not a readiness report, not an engineering gap analysis of your systems, and not a determination that any product meets a legal duty. Confirm current official text before you ship.

Last checked against official sources: 2026-10-11.

EU: Annex III employment systems

Annex III lists AI systems intended to be used for recruitment or selection, including targeted job ads, analysing and filtering applications, and evaluating candidates, and systems intended to be used to make decisions affecting terms of work, promotion, or termination, or to evaluate performance. Those systems are high-risk under Article 6 unless an Article 6 derogation actually fits. High-risk duties (risk management, data governance, technical documentation, logging, human oversight, accuracy) are a different backlog from Article 50. This page does not walk Annex IV.

Colorado: employment is a consequential decision

SB26-189 treats employment — access, eligibility, or compensation — as a consequential-decision domain. A covered ADMT that materially influences that decision needs developer documentation and deployer point-of-interaction notice from 1 January 2027, plus the 30-day adverse-outcome letter. Use the Colorado notice template as a drafting start, then wait for the Attorney General’s 1 January 2027 rules before you freeze the adverse-outcome letter.

What to tell a candidate tomorrow

If a person interacts with the system (a screening chatbot), Article 50(1) already required a disclosure from 2 August 2026. If a human never chats and a model only scores a PDF, 50(1) may not attach — Annex III and SB26-189 still might. Do not hide a ranker behind “our recruiters use modern tools.”

Questions teams ask

We only “assist” the recruiter. Are we out of Annex III?: Annex III covers systems intended to be used for those employment purposes, including analysing and filtering applications. “Assist” is not a statutory off-switch. Read the official Annex III wording for the exact system you sell.
Does AB 2013 apply to a hiring ranker?: Only if the ranker is a generative AI system or service under § 3110(c). A classifier that never generates synthetic content is outside AB 2013 and may still be inside Annex III and SB26-189.

Back to the AI law hub

Primary sources

Official text wins. Last checked 2026-10-11. This page is educational product guidance, not legal advice. It is not a readiness report, not an engineering gap analysis of your systems, and not a determination that any product meets a legal duty. Confirm current official text before you ship.