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What does human oversight of a high-risk AI system for HR mean in practice?

From 2 December 2027 you assign human oversight to people with the necessary competence, training and authority, who are given support. They must be able to monitor the operation, remain aware of the tendency to rely too much on the outcome, interpret the output correctly and, in any situation, decide not to use the outcome or to reverse it. A recruiter who just clicks 'agree' does not meet that.

Prepare; applies from 2 December 2027Trusq editorial · checked against the official textLast verified:

Next step: Record your HR AI tools in Trusq

Who exercises the oversight

You assign human oversight to natural persons who have the necessary competence, training and authority, and who get the necessary support [1]. Authority means that the person may actually deviate from the outcome.

What that person must be able to do

The system must be supplied so that the person overseeing it understands its capacities and limitations and can monitor its operation, remains aware of the tendency to rely too much on the output, can interpret the output correctly and can, in any situation, decide to disregard or reverse the output [2].

Who arranges what

The provider designs the system so that effective oversight is possible [3] and determines which measures you carry out as a deployer [4]. You follow those measures and the instructions for use. These duties start on 2 December 2027 [5].

In practice

Appoint an owner per process, give them time and instruction to investigate deviating outcomes, and record how often the human decision deviates from the system. That shows that the oversight is real.

What Trusq bases this on

These released rules are in Trusq and are read again with every publication; if a rule changes, this page changes with it.

  • Human oversight AI Act 14, AI Act 26

Sources

  1. [1] AI Act Art. 26(2) (AI Act, Regulation (EU) 2024/1689). Human oversight rests with persons who have the necessary competence, training and authority, with support.
    Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support.
    Source, retrieved on 3 October 2026.
  2. [2] AI Act Art. 14(4) (AI Act, Regulation (EU) 2024/1689). The persons overseeing must understand the capacities, know about automation bias, interpret the output and be able to deviate.
    4. For the purpose of implementing paragraphs 1, 2 and 3, the high-risk AI system shall be provided to the deployer in such a way that natural persons to whom human oversight is assigned are enabled, as appropriate and proportionate: (a) to properly understand the relevant capacities and limitations of the high-risk AI system and be able to duly monitor its operation, including in view of detecting and addressing anomalies, dysfunctions and unexpected performance; (b) to remain aware of the possible tendency of automatically relying or over-relying on the output produced by a high-risk AI system (automation bias), in particular for high-risk AI systems used to provide information or recommendations for decisions to be taken by natural persons; (c) to correctly interpret the high-risk AI system’s output, taking into account, for example, the interpretation tools and methods available; (d) to decide, in any particular situation, not to use the high-risk AI system or to otherwise disregard, override or reverse the output of the high-risk AI system;
    Source, retrieved on 3 October 2026.
  3. [3] AI Act Art. 14(1) (AI Act, Regulation (EU) 2024/1689). High-risk systems are designed so that effective human oversight is possible.
    1. High-risk AI systems shall be designed and developed in such a way, including with appropriate human-machine interface tools, that they can be effectively overseen by natural persons during the period in which they are in use.
    Source, retrieved on 3 October 2026.
  4. [4] AI Act Art. 14(3) (AI Act, Regulation (EU) 2024/1689). The provider determines oversight measures that are appropriate to be implemented by the deployer.
    (b) measures identified by the provider before placing the high-risk AI system on the market or putting it into service and that are appropriate to be implemented by the deployer.
    Source, retrieved on 3 October 2026.
  5. [5] Regulation (EU) 2026/1744 Art. 1(40)(b) (replaces AI Act Art. 113, third paragraph, point (c)) (Regulation (EU) 2026/1744 (Digital Omnibus on AI)). The high-risk rules (Chapter III, Sections 1 to 3) apply to Annex III systems from 2 December 2027.
    Chapter III, Sections 1, 2, and 3, with the exception of Article 6(5), shall apply from: (i) 2 December 2027 as regards AI systems classified as high-risk pursuant to Article 6(2) and Annex III; and
    Source, retrieved on 3 October 2026.

Related questions

What duties do we have from December 2027 as a deployer of a high-risk HR system?May software automatically reject applicants without a person looking at it?Do our employees need an AI literacy certificate or a mandatory course?What do we do if a high-risk AI system for HR does not work properly or causes a serious incident?

Next step

Register the AI tools you use in HR. Trusq shows per tool which duties may apply and sets them up as actions, with the evidence that is expected and the source.

Record your HR AI tools in Trusq

Looking for a specialist? We will look with you for a suitable specialist; mediation is not guaranteed.

This page gives general information based on the text of the law. It is not legal advice for your situation.