AI Hiring Tool: how does the European Union treat it?
HEAVILY REGULATED
High-risk by list position.
Recruitment and selection AI: targeted job ads, CV filtering, candidate evaluation, is Annex III high-risk: conformity assessment, human oversight, bias-controlled data governance, EU database registration. Obligations apply from 2 Dec 2027 (post-Omnibus).
Source: Annex III, point 4: AI Act: High-risk: employment & recruitment
The trapdoor: PROHIBITED
If the tool infers candidates' emotions, it's not regulated: it's prohibited.
Art. 5(1)(f) has been in force since Feb 2025: the ban applies today, not in 2027.
Source: Art. 5(1)(f): AI Act: Emotion-recognition ban
AI Hiring Tool: how does the United States treat it?
HEAVILY REGULATED
The most-regulated AI use case in America, without a federal AI law.
Title VII/ADA/ADEA disparate-impact liability stands (guidance withdrawn, statutes intact). NYC LL144 demands annual bias audits, Illinois AIVIA + HB 3773 cover interview and decision AI, Texas TRAIGA bans intentional discrimination, and Colorado's ADMT successor lands in 2027.
Source: Title VII: Civil Rights Act: disparate-impact liability; LL144: NYC Local Law 144: bias audits; AIVIA: Illinois AI Video Interview Act (820 ILCS 42); TRAIGA §552.056: Texas Responsible AI Governance Act
AI Hiring Tool: how does China treat it?
MOSTLY UNREGULATED
No dedicated employment-AI law.
Duties arrive sideways: PIPL Art. 24 grants explanation and refusal rights for automated decisions; public-facing platform features trigger CAC algorithm filing; Shanghai Art. 69 bars discriminatory conditions.
Source: PIPL Art. 24: PIPL: automated decision-making rights; S28: Fangda Partners: recruitment AI in China
The trapdoor
Foreign-hosted SaaS hiring tools typically can't pass the filing: they're quietly disabled or localized.