From regulation to governance: The EU AI Act and HR governance along the employee lifecycle

Abstract

Artificial intelligence (AI) is increasingly used in human resource management (HRM) to streamline processes, enhance decision-making and maintain competitiveness. At the same time, it raises critical concerns around transparency, discrimination, and employee autonomy, which are increasingly discussed in terms of AI governance and HR governance. The EU AI Act, which entered into force in late 2024, introduces a binding risk-based regulatory framework for AI systems and imposes significant obligations on companies that implement AI solutions in their business operations. Despite its relevance for both research and practice, a comprehensive analysis and conceptualisation of its implications for AI use in HRM from a governance perspective is yet missing. This paper addresses that gap by adopting a governance-oriented approach to AI use in HRM, structured along the questions ‘Who is governing?’, ‘What is governed?’, ‘When is it governed?’ and ‘How is it governed?’, and by developing an HR Governance × EU AI Act framework that systematically maps AI applications used in HR departments along the employee lifecycle to the Act’s prohibited, high-risk, and limited-risk classifications. In this context, it elaborates how external legal requirements should be translated into internal responsibilities, processes, and control mechanisms. Beyond this, the analysis examines whether established mechanisms such as works council codetermination can absorb new AI-related issues and whether European HR governance traditions converge under the Act. On this basis, we derive clear implications for employers and internal stakeholders regarding compliant implementation. We further discuss necessary regulatory and policy adaptations, focusing on national supervisory bodies to ensure compliance remains effective, feasible and supports the competitiveness of European companies. Overall, the study provides clear guidance for organisations using AI in HRM and offers a conceptual foundation for further academic research and discussion.