What is Annex III point 4 of the EU AI Act?

Annex III point 4 lists AI systems intended to be used for the recruitment or selection of people, for decisions affecting terms of work, promotion, or termination, for task allocation based on behaviour or traits, and for monitoring and evaluating performance of workers. Systems in this category are high-risk under Article 6(2) unless an Article 6(3) exemption is properly documented.

When do EU AI Act high-risk obligations start?

High-risk system obligations under the EU AI Act (Regulation 2024/1689) apply from 2 August 2026. Prohibited-practice provisions applied earlier. Exact timing for specific obligations is subject to guidance — verify with counsel.

What obligations apply once a workforce AI system is high-risk?

A high-risk classification triggers an obligation cascade: Article 9 risk management system, Article 10 data and data governance, Article 11 technical documentation, Article 13 transparency, Article 14 human oversight, Article 26 deployer obligations, and Article 27 fundamental rights impact assessment for deployers. Penalties under Article 99 reach up to EUR 15M or 3% of worldwide annual turnover for most high-risk violations (verify with counsel).

Does the EU AI Act apply to an India IT services exporter?

Yes, where the AI system's output is used in the EU or the provider places the system on the EU market, the EU AI Act applies regardless of where the provider is established. India IT services exporters building or operating workforce AI for EU customers may also need an Article 22 authorised representative. Verify with counsel.

EU AI Act Article 6 High-Risk Classifier — Interactive

EU AI Act Article 6 High-Risk Classifier

Answer 7 yes/no questions about your workforce-AI system and get an instant classification band — Not high-risk, Likely high-risk (Annex III point 4), or Definitely high-risk + obligations. Maps to EU AI Act Article 6(1) and Annex III point 4 (employment and worker-management), with the Article 9/10/14/27 obligation cascade. Built for EU and India-IT-exporter CISOs, DPOs, and counsel ahead of 2 August 2026 enforcement.

Is your workforce AI high-risk under the EU AI Act? A workforce-AI system used to recruit, evaluate, allocate work to, monitor, or make decisions affecting workers is classified as high-risk under EU AI Act Article 6(1) read with Annex III point 4. The Article 6(3) carve-outs for narrow procedural tasks, improving prior human activity, or preparatory tasks rarely apply once the system profiles individuals or influences an HR decision. High-risk obligations apply from 2 August 2026. This free classifier returns an indicative band only and is not a conformity assessment or legal advice — verify with qualified counsel.

Questions7 yes/no decision-tree

OutputClassification band + obligations

TimeUnder 3 minutes

FrameArt 6(1) + Annex III §4

How to use this

Answer each question Yes or No about the specific workforce-AI system you are assessing — the classification band updates the moment all seven are answered. Q1 confirms employment / worker-management use (the Annex III point 4 trigger), Q2–Q5 test profiling, decision influence, and sensitivity, and Q6–Q7 run the Article 6(3) exemption test. The result is indicative only. It is not a formal Article 6 determination or a conformity assessment — verify your classification with qualified counsel before acting. EU AI Act (Regulation 2024/1689) high-risk obligations apply from 2 August 2026.

Key facts (for citation)

Fact. EU AI Act Annex III point 4 lists AI used for recruitment or selection, decisions on work terms, promotion or termination, task allocation, and monitoring or evaluating worker performance as high-risk system categories.

Fact. Under Article 6(2), a system in an Annex III category is high-risk; Article 6(3) exemptions (narrow procedural task, improving prior activity, preparatory task) rarely apply once profiling is present.

Fact. High-risk obligations under the EU AI Act (Regulation 2024/1689) apply from 2 August 2026 — subject to guidance; verify with counsel.

Fact. A high-risk classification triggers Article 9 risk management, Article 10 data governance, Article 14 human oversight, and Article 27 fundamental-rights impact assessment, among other obligations.

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Instant classification
band updates as you answer

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Free to use
no email needed to see your band

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Full report (PDF)
classification trace + obligation cascade

EU AI Act Article 6 High-Risk Classifier — 7 questions

The interactive classifier above requires JavaScript. The seven yes/no inputs are reproduced below. All output is indicative only and must be verified with qualified counsel; high-risk obligations apply from 2 August 2026.

Q1. Is the AI system used in an employment or worker-management context — recruiting, evaluating, allocating work to, monitoring, or making decisions affecting workers? (Yes / No)

Q2. Does the system profile individuals or build behavioural or performance profiles of workers? (Yes / No)

Q3. Does the system make, or materially influence, HR or appraisal decisions (hiring, promotion, task allocation, discipline, termination), automatically or as decision support? (Yes / No)

Q4. Does the system process sensitive signals — biometric, emotion, continuous screenshot / keystroke / webcam / mic capture? (Yes / No)

Q5. Are the system's outputs used inside the EU, or is the system placed on the EU market? (Yes / No)

Q6. Does the system perform only a narrow procedural task and not affect the outcome of any decision (a candidate Article 6(3) exemption)? (Yes / No)

Q7. Does the system merely improve the result of a previously completed human activity, with no new profiling (a candidate Article 6(3) exemption)? (Yes / No)

Indicative classification band Not yet classified

Answer all 7

Mapped to Article 6(1) and Annex III point 4 (employment and worker-management).

Answer each question Yes or No — your indicative classification band appears once all seven are answered. Indicative only; verify with counsel.

Next step — read the decision tree, then email the full report

Read the EU AI Act Article 6 decision-tree analysis for the full Annex III point 4 scoping and Article 6(3) exemption traps, then score any vendor with the EU AI Act Vendor Scorecard. Want the classification trace and obligation cascade as a PDF? Email it to yourself below, or book a 30-minute readiness review with the gStride team.

Book a 30-min readiness review