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Recruitment and HR

ATS, candidate scoring and AI-assisted interviews at the heart of your business.

CandidatesATSDecisions about people

If you work in recruitment, AI is at the centre of your activity: CV screening, candidate scoring, assisted interviews. These are decisions that directly affect people, and that demands particular care. Alethexis helps you document each tool, maintain human oversight and keep a traceable record of how you work.

Where the Regulation places you

“AI systems intended to be used for the recruitment or selection of natural persons, in particular to place targeted job advertisements, to analyse and filter job applications, and to evaluate candidates” are high-risk under Annex III, point 4(a): an ATS that screens applications or a candidate-scoring tool falls squarely within it.

AI that plays no part in the decision on candidates — drafting job descriptions, scheduling interviews — is outside that point. Performance evaluation of people already employed is not outside either: it enters through point 4(b).

Obligation applicable from 2 December 2027 (Article 26, for high-risk systems under Annex III; Article 113, third paragraph, point (c), as worded by Regulation (EU) 2026/1744) — preparation recommended.

What to do today: inventory the ATS and the scoring tool, document the human oversight of each decision and keep a record of how they are used — that is what M3 documents.

Annex III: the eight high-risk areas under Article 6(2)Annex III to Regulation (EU) 2024/1689MAY FALL WITHIN HIGH RISK · CLASSIFICATION IS SYSTEM BY SYSTEM (ART.6)ANNEX III · AREAS UNDER ARTICLE 6(2)POINT 1Biometricsin so far as their use ispermitted under relevantUnion or national lawPOINT 2Critical infrastructurePOINT 3Education andvocational trainingPOINT 4Employment, workers’management and accessto self-employmentPOINT 5Access to andenjoyment ofessential privateservices and essentialpublic servicesand benefitsPOINT 6Lawenforcementin so far as their use ispermitted under relevantUnion or national lawPOINT 7Migration, asylum andborder controlmanagementin so far as their use ispermitted under relevantUnion or national lawPOINT 8Administration ofjustice and democraticprocessesAnnex III to Regulation (EU) 2024/1689 · Regulation (EU) 2026/1744 does not amend its eight areas
A system in these areas may fall within high risk; classification is done system by system (Article 6), against the specific letter of each point and its exceptions.
Read more: AI in recruitment: the high-risk zone arriving in December 2027

Royal Decree 723/2026: telling your workforce which systems decide on their work

Since 5 October 2026, Spain's Royal Decree 723/2026 requires employers to inform each worker in writing of the existence of algorithmic or automated decision-making systems, and of their guidelines, criteria and rules when they decide on working conditions. They do not need to be artificial intelligence or high-risk. In Alethexis, the inventory records which systems fall within that scope and the legal catalogue carries the references with their official Spanish text.

What Royal Decree 723/2026 requires →

Typical AI systems in the sector

ATS with AI

Automated screening and ranking of applications.

Candidate scoring

Assisted assessment for recruitment processes.

Assisted interviews

Support for competency assessment.

Illustrative examples. Alethexis classifies each system inside the platform, case by case, according to how you use it.

Start with the tools your sector uses.

When you register the use of an AI tool, Alethexis suggests the ones your sector typically uses — in Recruitment and HR, for example LinkedIn Recruiter, Cribado automático de candidaturas (ATS) and Entrevista o evaluación por vídeo — and fills in the name, the provider and a purpose you can change. The ones that usually require a high-risk assessment carry a notice, so they are not treated as closed before they are classified.

It does not classify, does not detect, and does not judge any tool. No "recommended" or "safe".

What worries you

  • Your tools affect people directly.
  • You need to maintain and demonstrate human oversight.
  • Your clients ask you for assurances about your use of AI.

How Alethexis supports you

  • Inventory with ATS and recruitment examples.
  • Documentation of human oversight in every process.
  • An auditable record to answer clients and candidates.

Reading for your sector

AI in recruitment: the high-risk zone arriving in December 2027High risk: what the Commission's classification guidelines aim to clarifyThe AEPD's Article 35(4) list: when your AI requires a DPIA even if it is not high-risk under the AI ActArticle 22 GDPR: the right not to be subject to an automated decision — and the three exceptions that allow oneFrom 5 October, your staff have the right to know which systems decide about their workArticle 64.4(d) of Spain's Workers' Statute: your works council already has the right to know which algorithms you use, and AI Act Article 26(7) will extend it in 2027

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