The AI Act: postponed, not cancelled

The problem: the delay does not apply to everything

Part of the regulation already applies. The prohibited practices in article 5 have applied since February 2025. The transparency obligations in article 50 have applied since August 2026, and since then national supervisory authorities have also been able to enforce the rules in practice. The AI literacy obligation remains, but the Omnibus shifts the focus from achieving a specific result to showing that you’re making the necessary efforts.

What matters more is what the delay does not change. The regulation asks for documentation you cannot pull together in the final month.

• A register: of the AI systems running inside your HR processes, including whatever comes in through your suppliers.
• Visibility on the data: what those models are trained on and fed with.
• Audit trails: of decisions in which an AI system played a part.
• Evidence of human oversight: in individual files, not only in your policy document.

That last point is the hardest one. You can only demonstrate human oversight if you can show who made which decision at what moment, and on the basis of what information. If that lives in a mailbox or in a recruiter’s head, you have no evidence afterwards and you are left reconstructing everything.

The approach: start with the register, not with the tooling

Start with an inventory. Which systems are running, who owns them internally, which decisions do they influence, and where does their data come from? Most organisations find AI in places they never thought of as using AI, such as the screening or matching that ships by default inside their recruitment tool.

After that it becomes a conversation between HR and IT, not just an IT responsibility. HR knows which decisions get made, IT knows where the data comes from. Together you decide which decisions you are willing to hand to a model and which ones you are not.

You are better off making those choices now than in the autumn of 2027, for three reasons. First, an audit trail only starts running on the day you set it up. So if you start late, you have no history to fall back on when the deadline arrives. Also, starting early gives you time to test that trail. You see which fields are missing or which decisions never make it in, and you can still fix that now without any consequences. And finally, the recruitment tools you buy or renew today will still be running in 2027. Whether you can export and log their decisions and the underlying data is something you are best off settling in the contract now.