TOPIC 03 OF 06
What high-risk duties look like
Oversight, data, documentationWhen a use lands in the high-risk band — things like employment, credit, essential services, or safety — a cluster of duties tends to follow: meaningful human oversight, attention to data quality and bias, documentation of how the system works and was tested, transparency to affected people, and record-keeping. You don't need to memorise the legal text to recognise the shape: high-risk means 'you must be able to show this is overseen, tested, and accountable.'
A hiring tool in the high-risk band can't just be switched on. Expect to keep a human deciding rejections, audit selection rates across groups, document the system, and be able to explain a decision to a candidate who asks.
These duties are not satisfied by a disclosure line or a good demo. If a use is high-risk, 'we told people we use AI' does not discharge the oversight, fairness, and documentation obligations. Confirm the specifics with qualified counsel — this is orientation, not legal advice.
For one higher-stakes use, list what you'd need to show a regulator or an affected person: who oversees it, how it was tested, and what you've written down.