Its recruitment-ranking purpose can place it within the EU: Which distinction determines the system’s EU AI
The changed purpose—from customer service to recruitment ranking—can move the system into the EU Act’s high-risk employment category.
The question
Assume the relevant EU AI Act duties apply. A retailer first uses a chatbot only to answer customer-service questions. It later connects the same system to recruitment records and ranks applicants for interviews. Which distinction determines the system’s EU AI Act risk analysis?
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- Its interface remains conversational, so its risk category remains unchanged.Risk analysis follows intended purpose and use, not merely the conversational interface or unchanged technical architecture.
- Its recruitment-ranking purpose can place it within the EU Act’s high-risk employment category. ✓Under the EU AI Act, intended purpose controls risk analysis, and recruitment or selection systems can be high-risk under applicable conditions.
- It becomes a general-purpose AI model because customers can ask varied questions.Broad user interaction does not by itself establish general-purpose model status or displace intended-purpose risk analysis.
- It requires only interaction disclosure because applicants communicate with software.Transparency may apply in context, but disclosure does not replace classification and controls associated with recruitment selection.
The trap
Classify the use that drives the decision, not the model’s original label or interface. How to remember it
The changed purpose—from customer service to recruitment ranking—can move the system into the EU Act’s high-risk employment category.
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