The handbrake has been pulled on aspects of the EU’s AI Act (Act), with key workplace rules, particularly those on high-risk systems, pushed back from August 2, 2026, to December 2, 2027. 

The delay may feel welcome for multinational employers keeping up with the spread of AI adoption across their organization, but it is an opportunity to get the groundwork done. 

The European Commission in late May published draft guidelines on the classification of high-risk AI systems (Guidelines, https://bit.ly/4vDtgOV) for the Act. This is the clearest indication yet of how EU workplace AI tools will be treated, using many real examples.

 To function efficiently across borders, business must incorporate these rules into their global compliance framework for legal, HR, talent acquisition, procurement, IT, data, compliance and operations. 

The extra months are useful runway, because HR, recruitment, performance management and workforce allocation tools will require the full gamut of “high-risk” systems compliance. Global employers need time to work this into a matrix of other global rules — including in multiple US jurisdictions (e.g., California, Colorado, Connecticut, New York), Canada, Korea’s Basic AI Act, the updated UK GDPR and emerging rules elsewhere. 

Below is a pragmatic look at what use cases trigger the Act, and what global employers need to do from governance, procurement, data protection and employee relations perspectives.