The EU AI Act in Action: What Employers Must Do Now and Next

two lawyers discussing the European Union AI Act

Artificial Intelligence (AI) is no longer the Wild West in Europe. The European Union’s AI Act, the world’s first comprehensive AI law, is now live and entering full implementation.

The Act has teeth. It’s to be phased in gradually through 2031, but the clock has already started ticking for employers. August 2025 marked a turning point: general purpose AI models (GPAI) like generative AI must now follow strict transparency obligations, governance rules and copyright safeguards.

If you run a business in Europe or hire anyone in the region, you can’t afford to treat this as background noise. The AI Act is reshaping how employers use AI in hiring, HR and workforce management. This is only the beginning.

In this blog, we provide some background information on the AI Act. We also break down what matters most for you right now, as well as in the future.

The AI Act: why it matters for employers

The AI Act was passed in 2024 to harmonize rules across the European Union. Its mission: promote innovation while protecting fundamental rights such as privacy, equality and democratic values.

This isn’t abstract regulation. It’s a risk-based approach to AI that directly impacts how you manage people, data, and technology.

Here’s the logic:

  • AI systems are classified by level of risk, from unacceptable risk (banned outright) to limited risks (minimal oversight).
  • High risk AI systems, such as those used in employment decisions, must undergo rigorous checks and conformity assessment before deployment.
  • Employers using AI based systems for recruitment, performance evaluation or workplace surveillance face new transparency obligations and stricter rules on fairness.

The stakes are high. Violating the AI Act can mean fines of up to €35 million or 7% of your global turnover. That’s not a slap on the wrist. It’s a business killer.

What changed in August 2025

We’re not in a waiting period anymore. The second wave of obligations hit on August 2, 2025. Here’s an overview of what that means:

  • General Purpose AI Models: If you use or integrate GPAI (e.g., generative AI tools, chatbots or algorithmic screening platforms), you must ensure providers follow EU transparency rules. Technical documentation, copyright disclosures and system summaries are now mandatory.
  • Transparency Obligations: All AI-generated outputs must be labeled. That includes résumés screened by AI, recruitment messages or automated performance feedback. Candidates and employees have a right to know when AI is in play.
  • Codes of Practice: The European Commission has issued voluntary codes of practice for GPAI providers. While “voluntary,” adopting them provides legal certainty and may lighten administrative burdens.
  • Governance and Accountability: Employers must designate responsible persons, maintain audit trails and report serious AI-related incidents. You’re now accountable not just for how AI works, but how it impacts people.
  • National Authorities: Each Member State has set up contact points and enforcement bodies. You now have regulators watching closely, not just in Brussels but locally.

In plain terms: the rules are real, the watchdogs are live and employers are officially on the hook.

What you should do right now

Following the recent wave of new regulations, here’s your action plan for the last half of 2025:

  • Inventory Your AI Systems: Document use cases, risk levels and provider compliance.
  • Label all AI-Generated Outputs: From job ads to chatbot responses, make transparency standard practice.
  • Update Governance Structures: Appoint responsible persons, establish audit trails and prepare for conformity assessments.
  • Expand AI Literacy Programs: Train your HR teams, managers and decision-makers.
  • Engage With Codes of Practice: What’s voluntary now will likely prove to be strategic in the future. Stay ahead of the curve.
  • Partner Smart: A global business solutions provider with global capabilities and local execution can help stay ahead of compliance across the EU.

What’s coming next (2026–2031)

If these recent regulations felt like a wake-up call, the next milestones will test your compliance muscle:

  • February 2026: The European Commission to issue guidance on how to implement Article 6, including post-market monitoring of high-risk AI systems.
  • August 2026: Operators of high-risk AI systems must comply with most obligations and national AI sandboxes must be up and running.
  • August 2027: Providers of GPAI models placed on the market before August 2025 must comply in full.
  • 2030–2031: Full compliance deadlines to hit for public authority use, large-scale IT systems and final enforcement reviews.

The timeline seems long, but don’t let that fool you. Employers need to prepare now to avoid costly disruption later.

Key compliance areas for employers

Here’s a framework for where you need to focus on through 2031 as the AI Act rolls out in phases:

  1. Classify Your AI Systems by Risk: Audit every AI based tool you use in hiring, payroll and HR. Classify each system by level of risk. Are you using high-risk AI systems for candidate screening? Or limited risks like chatbots answering FAQs? This step is non-negotiable.
  2. Manage High-Risk AI Systems: If your systems fall into the high-risk category, you’ll need a conformity assessment. That means documented risk analysis, human oversight, data governance and ongoing monitoring. Don’t wait until 2026. Start aligning now.
  3. Respect Transparency Obligations: Employees and candidates must know when AI is involved in decisions that affect them. Label AI-generated communications. Document your processes. Build trustthrough clarity, not secrecy.
  4. Align with GDPR: The AI Act complements the General Data Protection Regulation (GDPR). Together, they create a double layer of compliance. Make sure your data governance policies respect both privacy and AI obligations.
  5. Train Your People: AI literacy is now a legal requirement. Staff interacting with or overseeing AI must be trained. This isn’t optional. It’s a key part of your compliance framework.
  6. Build Internal Codes of Practice: Don’t wait for regulators to knock. Draft internal codes of practice now. Update them regularly as new obligations roll out.

The business case: compliance as strategy

Let’s be clear: the AI Act is not just red tape. Done right, compliance becomes a competitive advantage because it:

  • Protects you from financial and reputational damage.
  • Reassures employees and candidates that you respect their rights.
  • Positions your brand as a responsible, ethical employer in a market where talent increasingly values trust.

In a world where half of jobs may be disrupted by AI (IMF projections), companies that manage AI responsibly will win the talent war.

Don’t go it alone: how local expertise can help

No international company should face the EU AI Act alone. The rules are complex. The penalties are severe. When your operations stretch across borders, compliance gets even trickier.

That’s why many organizations lean on a global business solutions provider. The right partner cuts through regulatory complexity and keeps every part of your business aligned with both local law and EU-wide rules.

The AI Act isn’t limited to recruitment or HR—it ripples across your entire organization. Entity structures must be set up and governed in ways that withstand regulatory scrutiny. HR functions (e.g., recruitment, onboarding, payroll, benefits) now come with AI transparency and accountability requirements. Even finance operations (from accounting and tax to cross-border payments) must ensure audit-ready records when AI systems are involved.

Meeting these obligations requires more than a checklist. It takes global reach, local execution and the right mix of expertise across legal, HR and finance. With that support, you can navigate AI compliance confidently, while protecting your people, your reputation and your growth.

The road ahead: turning AI compliance into opportunity

We’re still at the start of a long journey. By 2031, the AI Act will be fully operational. Between now and then, rules will tighten, audits will expand and new guidance will emerge.

Your choice is simple: Do you scramble to react later or prepare strategically today?

Employers who embrace compliance as part of their culture will thrive. Those who ignore it risk fines, reputational harm and broken trust. AI isn’t going away, but the days of unchecked AI use in the workplace are over.

The future belongs to businesses that balance innovation with responsibility. If you’re ready to lead, now is the time to act.

Contact us to discover how our proven global business solutions simplify compliance and keep your operations AI-ready.

The content provided in this publication is for general information purposes only and should not be considered legal advice. Due to potential changes in regulations, the information may become outdated. GoGlobal and its affiliates disclaim any responsibility for actions taken or not taken based on the information contained in this publication.

Our Latest Insights

See all Resources

Case Studies

The power of one employee in a high-stakes transaction

Sonoco is a global leader in sustainable metal and fiber consumer and industrial packaging. With 285 operations across 40 countries and 23,000+ employees, the company supports customers and communities worldwide

three colleagues discussing employee benefits while walking

Blog

30 unique employee benefits to attract global talent in 2026

A strategic guide for global employers Global hiring has become more competitive, more distributed and far more employee-driven than it was just a few years ago. For employers expanding internationally,

two professional women looking at a laptop together

Blog

De-risking the exit: why international compliance gaps impact portfolio company valuations

Exit value is not only driven by growth. It is shaped by how clean, consistent and defensible your operations look under scrutiny. Exit processes tend to move fast. But due

1/5