A recent study shows that German companies have so far rarely deployed AI in human resources, with data protection concerns and uncertainty about the specific requirements of the EU AI Act cited as decisive factors.
According to the underlying survey, the use of Artificial Intelligence in HR processes at German companies remains the exception so far. Respondents cite as the main reasons concerns about handling sensitive personnel data as well as a lack of clarity on how the requirements of the EU AI Act specifically apply to HR applications. Personnel data is considered particularly worthy of protection under the GDPR, and many AI-supported HR applications, such as automated applicant selection or performance evaluation, potentially fall into the category of high-risk AI systems under the EU AI Act, which are subject to stricter compliance requirements.
For CDOs, this reluctance is a relevant signal: it shows that legal uncertainty slows down investment decisions even where the economic benefits of AI applications are undisputed. HR processes are among the areas with high automation potential, for example in the pre-selection of applications or workforce planning. If the regulatory classification remains unclear, a dilemma arises between the risk of delayed digitalization and the risk of legal or reputational consequences from premature implementation.
In practice, this means that companies should carry out a careful risk classification under the EU AI Act before introducing AI into HR processes, combined with documentation of a data protection impact assessment under the GDPR. Cooperation between compliance, data protection and HR departments thus becomes a prerequisite for identifying use cases that can be implemented in a legally compliant manner with reasonable effort, rather than postponing adoption altogether.
German companies are cautious about using AI in human resources due to data protection concerns and uncertainties surrounding the EU AI Act.
Source: www.golem.de · Published August 19, 2026
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