Insights
AI in Recruitment: What to Watch Under KVKK and the EU AI Act
September 24, 2026
AI tools that screen CVs and rank candidates save time in recruitment. The same tools are among the AI uses that need the most legal care. This article is not legal advice; it offers a general framework.
EU AI Act: Annex III of Regulation (EU) 2024/1689 lists as high-risk the “AI systems intended to be used for the recruitment or selection of natural persons, in particular to place targeted job advertisements, to analyse and filter job applications, and to evaluate candidates” (Annex III, point 4(a); Regulation text).
Timeline: According to the European Commission, the “AI Omnibus” entered into force on July 27, 2026; rules for stand-alone high-risk systems in Annex III apply from December 2, 2027 (European Commission, 27.07.2026). Because the Regulation can also cover systems established outside the EU whose output is used in the EU, it matters for Turkish companies working with candidates in the EU.
KVKK (Türkiye): Article 11 of Law No. 6698 gives data subjects the right to object to a result against them arising from the analysis of their data exclusively by automated systems (Law No. 6698).
Principles we recommend in practice
- A person makes the final decision: The tool ranks and summarizes; the hiring team decides.
- Explicit criteria: Put your assessment criteria in writing and apply the same criteria to every candidate.
- Transparency: Give applicants a notice explaining for what purpose and with which tools their data is processed.
- Data minimization: Do not request special categories of personal data; exclude them from assessment if they appear in application documents.
- Logging and review: Record the tool’s suggestions and the decisions made, and review outcomes periodically.
CV.keywork.ai ranks candidates against the criteria you define and provides summary reports; the final assessment stays with your hiring team. Information: support@keywork.ai