Annex III section 4 + NYC AEDT + IL HB 3773 + GDPR Art 22. One substrate.

Annex III section 4 designates AI used in employment, workers management, and access to self-employment as high-risk: recruitment and selection (CV screening, ranking, filtering), and AI used to make or materially influence decisions on terms, promotion, termination, task allocation, and performance/behaviour monitoring. High-risk status triggers Article 9–15 obligations (risk management, data governance, transparency, human oversight, logging) plus Article 26 deployer duties. MEOK ships the Annex IV technical documentation and oversight evidence as one signed pack.

If you use an Automated Employment Decision Tool to substantially assist hiring or promotion of NYC candidates, Local Law 144 requires: an independent bias audit within the past year, a publicly posted summary of the audit results and the tool's distribution date, and notice to candidates at least 10 business days before use (with the data categories and source). Penalties are per-violation, per-day. Our bias-detection MCP produces the impact-ratio audit by sex, race/ethnicity, and intersectional categories that the audit standard expects.

Illinois has two layers. The earlier Artificial Intelligence Video Interview Act requires candidate consent before AI analyses a video interview, deletion within 30 days on request, limits on sharing, and demographic reporting where AI alone decides who advances. HB 3773 (effective Jan 2026) amends the Illinois Human Rights Act to make it a civil-rights violation to use AI that discriminates in employment decisions or to use ZIP code as a proxy, and adds notice duties. You need consent, deletion, bias auditing, and notice — our HR pack covers all four.

Article 22 gives individuals the right not to be subject to a decision based solely on automated processing — including profiling — that produces legal or similarly significant effects, such as rejecting a job application. Solely-automated hiring is only lawful under narrow exceptions (explicit consent, contract necessity, or authorising law) and even then you must provide meaningful human review, the ability to contest, and an explanation. In practice HR AI must keep a human in the loop with genuine authority to override. We map Article 22 review rights onto your workflow logs.