AI in recruitment for logistics: is it high-risk under the AI Act?
Adopted 2026-06-16 · ≈ 1 min read · 
edited by Dirk Baaijen
Yes. AI systems used in logistics for recruiting and selecting staff fall under Annex III of the AI Act and count as high-risk. The heaviest duties apply in phases; AI literacy already applies now.
Short answer: Yes, as a rule. AI systems you use to recruit, screen, or select candidates for logistics roles fall under Annex III of the AI Act and therefore count as high-risk — regardless of the sector you operate in.
Why recruitment counts as high-risk
Annex III of the AI Act (Regulation (EU) 2024/1689) explicitly names "employment, workers management and access to self-employment" as an area where AI systems are high-risk. This covers systems used to recruit or select people, in particular to place targeted job advertisements, to analyse and filter applications, and to evaluate candidates. For a logistics company looking for drivers, planners, or warehouse staff, the fact that it concerns transport makes no difference: it is the recruitment and selection function itself that drives the classification, not the industry.
What counts as such a system?
What matters is the actual function. An AI tool that ranks CVs, scores applicants, automatically rejects or pre-selects them, or that shows job ads to particular target groups, falls into this category. A purely administrative aid that merely records or forwards applications without influencing the assessment sits outside it. The question is always: does the system affect who is hired or rejected? If so, it is prudent to assume a high-risk classification.
What this means for you
A high-risk classification brings obligations, such as risk management, data quality, technical documentation, human oversight, and transparency towards the people concerned. These Annex III obligations apply in phases; the European Commission publishes the current timeline. Independently of that, the AI literacy duty (Art. 4) has applied since 2 February 2025: staff who operate the recruitment system must understand how it works and where its limits lie. Note too that the GDPR continues to apply in full to the processing of applicant data.
Read more: AI Act: timeline of obligations. Take the scan.
Sources
- https://eur-lex.europa.eu/eli/reg/2024/1689/oj
Regulation (EU) 2024/1689 (AI Act); Annex III classifies employment and workforce management as high-risk. - https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai
European Commission — overview of the AI regulatory framework and the risk-based approach.
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