How HR Can Prepare for the EU AI Act and Emerging Regulations Globally

How HR Can Prepare for the EU AI Act and Emerging Regulations Globally
September 9, 2026 7 mins

How HR Can Prepare for the EU AI Act and Emerging Regulations Globally

How HR Can Prepare for the EU AI Act and Emerging Regulations Globally

The EU AI Act is the world’s first comprehensive, binding law governing AI. For multinationals with employees in the EU, it raises important questions about how AI is used across the workforce. It also serves as a blueprint for new regulations across the globe.

Key Takeaways
  1. As AI becomes embedded in workforce decisions, regulation is increasing accountability for how it’s governed and applied across HR processes.
  2. Emerging regulations call for companies to identify where AI is used, assess its impact on employees and prioritize high-risk use cases.
  3. Building effective governance frameworks will require coordination between risk and HR, as well as transparency and accountability when working with third-party providers.

As artificial intelligence (AI) becomes more embedded in workforce processes, HR is becoming increasingly responsible for understanding how it is used in employment decisions. According to Aon’s 2026 Human Capital Trends Study, 49% of organizations identify HR as a top area for AI deployment, second only to IT, while 65% of HR departments have already implemented at least one AI-based tool. At the same time, 37% cite ethical, legal and regulatory concerns as a barrier. This underscores growing tension between adoption and accountability. 

New and emerging regulations are placing greater scrutiny on how AI is used in the workforce. While some jurisdictions already have laws governing automated employment decisions, the EU AI Act1 introduces a broader, risk-based framework with explicit requirements for higher-risk AI systems, including those used in employment. While the Act applies directly within the EU, its implications extend beyond — setting a precedent that is already shaping regulatory approaches across other regions. While key obligations will phase in over time, organizations need to act now to build the foundations required for compliance.

HR Requirements Under the EU AI Act 

The EU AI Act introduces a risk-based framework that classifies AI systems based on their potential impact. For HR teams, this has significant implications. Using AI in recruitment, promotion, pay decisions and performance management processes can fall within the "high-risk" category, where it materially influences employment outcomes.

This classification introduces clear legal obligations and accountability for employers. They are now expected to understand not only where AI is being used, but how it works and what safeguards are in place. This includes understanding how decisions are made, ensuring fairness and non-discrimination, and providing transparency to employees affected by AI-driven processes.

In practice, this means moving beyond experimentation and into structured governance. Companies will need to take several foundational steps:

  • Inventory HR AI systems and document how AI-driven decisions are made.
  • Classify systems according to the risk level of high, medium and low.
  • Strengthen due diligence over third-party vendors.
  • Control how AI tools are used. Expanding them beyond their original purpose can change their risk categorization and trigger additional regulatory obligations.
  • Build governance frameworks that support oversight.

These actions are not one-off exercises. They represent the beginning of a more continuous, evidence-based approach to managing AI in the workforce — one that will evolve as requirements change. Beyond these high-level actions, the Act also introduces more specific expectations around what employers must be able to demonstrate in practice.

28%

of organizations have fully operational AI governance frameworks in place.

Source: Aon's 2026 Human Capital Trends Study

Aon's EU AI Act Guide

Guide

Aon's EU AI Act Guide

While the EU AI Act provides an important starting point, many organizations are grappling with a broader question: How should they govern AI across a global workforce as regulatory expectations continue to evolve? Aon's EU AI Act Guide explores the implications of the Act in greater depth and examines emerging trends that employers should monitor as they build their AI governance approach.

AI Regulation is Evolving as Governance Expectations Converge

While the EU AI Act is one of the most comprehensive AI regulations currently in force, it is only one part of a rapidly evolving global landscape. Around the world, governments, regulators and private bodies are taking different approaches to AI oversight, ranging from comprehensive legislation to voluntary frameworks and sector-specific guidance.

While the specifics continue to change, many are placing greater emphasis on transparency, accountability, risk management and human oversight when AI influences workforce decisions. For multinational employers, the challenge is not simply complying with a single regulation, but building governance frameworks that can adapt as requirements continue to evolve.

“The most effective response to a changing regulatory landscape isn't to focus on a single rule or jurisdiction," says Charlotte Schaller, Partner, Head of Assessment, Talent Solutions, United Kingdom. “It's to build a governance approach that helps organizations understand their AI use, assess risk and make confident decisions as expectations continue to evolve."

4 Core Principles Emerging Across Regulations

For multinational employers, the most important trend is not the differences between regulations, but the common expectations beginning to emerge across them.

  1. There is a greater focus on higher-risk uses of AI in the workforce. Scrutiny is often directed at AI-supported tools that influence employment outcomes, particularly hiring, assessment, performance management and other workforce decisions with a significant impact on individuals. Organizations are increasingly expected to understand where these systems are used, assess associated risks and apply appropriate safeguards.
  2. Organizations are expected to understand and document how AI is used. A common expectation emerging across jurisdictions is that employers maintain visibility over their AI use. This includes identifying AI tools in use, understanding how they influence decisions and documenting their purpose, data sources and potential risks. Effective governance starts with building a clear inventory of AI systems and their impact on workforce processes.
  3. Responsibility extends beyond the AI provider. Many regulatory and governance frameworks increasingly reinforce that organizations remain accountable for how AI is used in their own environment. That means strengthening vendor due diligence, understanding how AI tools operate and ensuring appropriate oversight rather than relying solely on provider assurances.  
  4. Governance, oversight and accountability are becoming business priorities. While regulations differ, many emphasize the need for structured governance, clear ownership and human oversight when AI influences workforce decisions. Organizations are increasingly expected to establish governance frameworks that support ongoing monitoring, risk management and responsible AI adoption as requirements continue to evolve.

Regardless of where an organization operates today, the foundations of AI governance are becoming clearer. Employers should understand where AI is used, assess higher-risk workforce applications, strengthen oversight of third-party providers and establish governance structures that can adapt as requirements evolve. Organizations that start building these capabilities now will be better positioned to respond to future regulatory change.

This is particularly important when working with third-party vendors. External AI providers introduce shared accountability and additional risk exposure related to data use, transparency and accountability. As reliance on these tools grows, organizations must prioritize due diligence, define clear ownership and ensure that governance standards extend across their vendor ecosystem.

Quote icon

For HR leaders, the EU AI Act can be seen as a catalyst for change. It signals a shift toward more accountable, transparent and structured use of AI in the workforce.

Maggie You
Partner & Head of People Advisory, Human Capital M&A, APAC

Aon can help organizations map their systems, align global governance and embed strong risk management into their operations. Start a conversation.

Aon's Thought Leaders

Steven Guyer
Head of Rewards and Career Advisory, Talent Solutions, North America

Charlotte Schaller
Partner, Head of Assessment, Talent Solutions, United Kingdom

Maggie You
Partner, Head of People Advisory, Talent Solutions, Asia Pacific

 

1 EU Artificial Intelligence Act

General Disclaimer

This document is not intended to address any specific situation or to provide legal, regulatory, financial, or other advice. While care has been taken in the production of this document, Aon does not warrant, represent or guarantee the accuracy, adequacy, completeness or fitness for any purpose of the document or any part of it and can accept no liability for any loss incurred in any way by any person who may rely on it. Any recipient shall be responsible for the use to which it puts this document. This document has been compiled using information available to us up to its date of publication and is subject to any qualifications made in the document.

Terms of Use

The contents herein may not be reproduced, reused, reprinted or redistributed without the expressed written consent of Aon, unless otherwise authorized by Aon. To use information contained herein, please write to our team.

Aon's Better Being Podcast

Our Better Being podcast series, hosted by Aon Chief Wellbeing Officer Rachel Fellowes, explores wellbeing strategies and resilience. This season we cover human sustainability, kindness in the workplace, how to measure wellbeing, managing grief and more.

Aon Insights Series Asia

Expert Views on Today's Risk Capital and Human Capital Issues

Aon Insights Series Pacific

Expert Views on Today's Risk Capital and Human Capital Issues

Aon Insights Series UK

Expert Views on Today's Risk Capital and Human Capital Issues

Client Trends 2025

Better Decisions Across Interconnected Risk and People Issues.

Construction and Infrastructure

The construction industry is under pressure from interconnected risks and notable macroeconomic developments. Learn how your organization can benefit from construction insurance and risk management.

Cyber Resilience

Our Cyber Resilience collection gives you access to Aon’s latest insights on the evolving landscape of cyber threats and risk mitigation measures. Reach out to our experts to discuss how to make the right decisions to strengthen your organization’s cyber resilience.

Employee Wellbeing

Our Employee Wellbeing collection gives you access to the latest insights from Aon's human capital team. You can also reach out to the team at any time for assistance with your employee wellbeing needs.

Environmental, Social and Governance Insights

Explore Aon's latest environmental social and governance (ESG) insights.

Q4 2023 Global Insurance Market Insights

Our Global Insurance Market Insights highlight insurance market trends across pricing, capacity, underwriting, limits, deductibles and coverages.

Global Risk Management Survey

Better Decisions Across Interconnected Risk and People Issues.

Regional Results

How do the top risks on business leaders’ minds differ by region and how can these risks be mitigated? Explore the regional results to learn more.

Impact Report 2025

Explore Aon's corporate sustainability impact and strategy.

Top 10 Global Risks

Trade, technology, weather and workforce stability are the central forces in today’s risk landscape.

Industry Insights

These industry-specific articles explore the top risks, their underlying drivers and the actions leaders are taking to build resilience.

Human Capital Analytics

Our Human Capital Analytics collection gives you access to the latest insights from Aon's human capital team. Contact us to learn how Aon’s analytics capabilities helps organizations make better workforce decisions.

Human Capital Quarterly Insights Briefs

Read our collection of human capital articles that explore in depth hot topics for HR and risk professionals, including using data and analytics to measure total rewards programs, how HR and finance can better partner and the impact AI will have on the workforce.

Insights for HR

Explore our hand-picked insights for human resources professionals.

Workforce

Our Workforce Collection provides access to the latest insights from Aon’s Human Capital team on topics ranging from health and benefits, retirement and talent practices. You can reach out to our team at any time to learn how we can help address emerging workforce challenges.

Mergers and Acquisitions

Our Mergers and Acquisitions (M&A) collection gives you access to the latest insights from Aon's thought leaders to help dealmakers make better decisions. Explore our latest insights and reach out to the team at any time for assistance with transaction challenges and opportunities.

Natural Resources and Energy Transition

The challenges in adopting renewable energy are changing with technological advancements, increasing market competition and numerous financial support mechanisms. Learn how your organization can benefit from our renewables solutions. 

Navigating Volatility

How do businesses navigate their way through new forms of volatility and make decisions that protect and grow their organizations?

Parametric Insurance

Our Parametric Insurance Collection provides ways your organization can benefit from this simple, straightforward and fast-paying risk transfer solution. Reach out to learn how we can help you make better decisions to manage your catastrophe exposures and near-term volatility.

Pay Transparency and Equity

Our Pay Transparency and Equity collection gives you access to the latest insights from Aon's human capital team on topics ranging from pay equity to diversity, equity and inclusion. Contact us to learn how we can help your organization address these issues.

Property Risk Management

Forecasters are predicting an extremely active 2024 Atlantic hurricane season. Take measures to build resilience to mitigate risk for hurricane-prone properties.

Technology

Our Technology Collection provides access to the latest insights from Aon's thought leaders on navigating the evolving risks and opportunities of technology. Reach out to the team to learn how we can help you use technology to make better decisions for the future.

Trade

Our Trade Collection gives you access to the latest insights from Aon's thought leaders on navigating the evolving risks and opportunities for international business. Reach out to our team to understand how to make better decisions around macro trends and why they matter to businesses.

Transaction Solutions Global Claims Study

Better Decisions Across Interconnected Risk and People Issues.

Weather

With a changing climate, organizations in all sectors will need to protect their people and physical assets, reduce their carbon footprint, and invest in new solutions to thrive. Our Weather Collection provides you with critical insights to be prepared.

Workforce Resilience

Our Workforce Resilience collection gives you access to the latest insights from Aon's Human Capital team. You can reach out to the team at any time for questions about how we can assess gaps and help build a more resilience workforce.

More Like This

View All
View All
Subscribe CTA Banner