AI governance for recruitment firms
Recruitment sits at the intersection of heavy AI adoption, candidate personal data and client procurement scrutiny. This is what governance looks like in practice, control by control.
Start with the inventory
List every AI tool consultants use, including the AI built into your CRM, ATS, sourcing tools and email. Mark which ones touch candidate data and which ones screen, rank or evaluate people.
Candidate-facing systems deserve special attention
The main requirements for standalone high-risk systems are scheduled to apply from 2 December 2027. Systems used to analyse, filter or evaluate people in an employment context fall within the high-risk employment category, subject to the relevant legal conditions.
Consultant AI literacy
AI literacy obligations have applied since 2 February 2025. Firms using AI should be able to show what measures they have taken to help relevant staff use it responsibly.
Transparency
From 2 August 2026, specific AI interactions and certain AI-generated or manipulated content must be disclosed or marked. Whether that applies depends on how the system is used. National authorities also begin exercising relevant enforcement powers from this date.
Policy and ownership
One acceptable-use policy that consultants have actually signed, and one named person accountable for oversight. Both are questions on supplier questionnaires.
Evidence a client can check
A public trust profile turns all of the above into something a client can verify without a call. Early adopters may have an opportunity to differentiate in supplier reviews before verifiable AI governance becomes standard.
Applicability
Applicability depends on the AI system and how you use it. EUQA helps you document and evidence your position; it is not legal advice.