EU AI Act Annex III point 4 (employment, workers management, recruitment) applies to SMB AI hiring use even at four-employee scale; the threshold does not scale with company size, and the 2 August 2026 enforcement window covers AI-screened CVs in ChatGPT/Claude/Gemini the same way it covers dedicated platforms (Workable, Greenhouse, Lever, BrightHire). The defensible posture is AI-assisted decisions with a documented human decision-maker plus retained AI-output records — not AI-decided hiring. Solely-automated candidate scoring also conflicts with GDPR Article 22; ICO, AP, and Garante guidance from 2024-2025 is consistent on the human-in-the-loop requirement.
Cross-domain: EU AI Act Annex III point 4 hiring categories intersected with SMB tooling reality. Statutory anchors: EU AI Act Regulation 2024/1689 Annex III + Article 99 penalties; GDPR Article 22 right not to be subject to solely automated decisions. Regulatory guidance: ICO AI in recruitment 2024, Dutch AP 2025 framework, Italian Garante 2024 ruling against AI scoring without disclosure. The deployer-side documentation (named human decision-maker + retained AI-output records + AI-disclosure in job advertisements) is what survives the audit at SMB scale. Pairs with AM-120 at the multinational works-council surface and OPS-038 at the SMB collective-agreement surface.
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About this register
The Operators register tracks claims published from practitioner-advisory pieces addressed to solo founders, micro-SMB, and small businesses up to around fifty people. Claims are reviewed on a 30–45 day cadence — tooling and SMB-relevant pricing shift faster than enterprise procurement signals.
Recent corrections in Operators
- OPS-036 · Partial · 29 Apr 2026
Initial publication 29 Apr 2026. Status set to Partial at publication because clause 6 commentary references an order-of-magnitude remediation-cost gap derived from the IAPP 2024 AI Governance Profession Report; the report characterises the gap as material but does not publish a precise multiple, so the wording is annotated source: our-estimate. REVIEW: Peter to source a precise figure or amend the commentary.
- OPS-035 · Holding · 29 Apr 2026
Initial publication 29 Apr 2026. Status set to Partial at publication because category 5 lacks the same regulatory/cited-consequence anchor as categories 1-4. REVIEW: Peter to confirm category 5 evidence base and either upgrade to Holding (with strengthened citation) or amend the claim to four categories.
- OPS-034 · Holding · 29 Apr 2026
Initial publication 29 Apr 2026 with status=partial. Cost-side claims (vendor pricing) verifiable against the four cited pricing pages on the publication date. Time-recovery claim (90+ min compressed to ~20 min) drawn from published productivity-blogger benchmarks rather than Peter-run measurement; first-cohort replication on the publication's tracked operator cohort due by 13 Jun 2026. REVIEW: Peter.
Reviews coming up in Operators
- OPS-005 · Holding · next +12d (26 May 2026)
At sub-1M tokens per month (typical SMB agent volume) in 2026, the absolute dollar gap between Claude Haiku 4.5, GPT-4o…
- OPS-003 · Holding · next +12d (26 May 2026)
For a solo founder choosing exactly one consumer AI subscription at around $20/month in 2026, the choice between Claude…
- OPS-002 · Holding · next +12d (26 May 2026)
For a 5-person consultancy already on either Notion or ClickUp in 2026, the AI features alone do not justify a workspac…