Reg (EU) 2024/1689Generate dossier — €249

You provide an AI video interview tool. Article 5 bans emotion recognition in the workplace. Annex III.4(a) classifies candidate assessment as high-risk. Jobma publishes a compliance badge. You need Annex IV documentation. Those are different things.

The AI Act draws two lines for video interview AI. Line one: Article 5.1(f) prohibits emotion recognition systems in the workplace and education — if your tool infers emotions from facial expressions during interviews, it is banned, not just high-risk. Line two: if your tool assesses candidates through speech analysis, behavioural cues, or structured response scoring without emotion recognition, it falls under Annex III.4(a) — high-risk, documentable. AICheck generates the twelve-document Annex IV file for your system. 45 minutes. €249. Browser-side.

Generate Annex IV dossier — €249Free: check if your system is high-risk

€249 one-time · 12-document ZIP · 45 minutes · Browser-side

Regulation (EU) 2024/1689 · Article 11 + Annex IV · 12 documents · 100% browser-side — your data never leaves your device

Video interview AI: prohibition vs documentation

The AI Act distinguishes between banned and documentable video interview AI. Know where your tool stands.

Art. 5.1(f)
Emotion recognition in workplace = BANNED
Annex III.4(a)
Candidate assessment without emotion recognition = high-risk = documentable
12 docs
Annex IV file AICheck generates from your system data

What AICheck does with your HR system data

You enter your system data. AICheck structures the documentation per all nine Annex IV points.

1
Company data
Legal name, role under the Regulation (provider), HR tech sector, market of deployment.
2
Article 5 check
Confirms your HR system does not fall under prohibited practices (emotion recognition in workplace, social scoring).
3
Annex III classification
Confirms Annex III category 4 classification: (a) recruitment/screening, (b) terms and conditions, (c) performance monitoring, or (d) task allocation.
4
Annex IV points 1–5
General description, intended purpose, hardware interaction, previous versions, dependencies.
5
Annex IV points 6–9
Training data, performance metrics, risk management, human oversight.
6
EU Declaration of Conformity
Per Article 47 and Annex V. Signable document.
7
ZIP download
12 PDF documents. Generated in your browser. No data leaves your device.

Three mistakes HR tech companies make

COMMON MISTAKE

"Our tool analyses facial micro-expressions but it's not emotion recognition"

The Regulation defines emotion recognition (Art. 3(39)) as inferring emotions or intentions from biometric data. If your tool analyses facial expressions, voice tone, or micro-movements to draw conclusions about a candidate's state, it likely falls under the Art. 5.1(f) prohibition. This is not a documentation question — it is a legality question. Use the AICheck checker first.

COMMON MISTAKE

"Jobma is compliant, so video interview AI must be fine"

Jobma publishes a compliance statement for their own product. That covers their system, not yours. If you build a different video interview tool, your system needs its own Annex IV documentation. A competitor's compliance badge is not transferable.

COMMON MISTAKE

"We only record the interview — the AI analyses the transcript"

If the AI analyses the transcript to score, rank, or evaluate candidates, the system is in scope under Annex III.4(a). The modality (video analysis vs transcript analysis) does not change the classification. What matters is whether the AI output influences hiring decisions.

What the ZIP contains

12 PDF documents generated from your data. Each cites the specific article of Regulation (EU) 2024/1689 it complies with.

1

Risk Classification

Identifies your system under Annex III category 4. Art. 6 + Annex III.

2

Annex IV Technical Documentation

All 9 points. Art. 11 + Annex IV.

3

EU Declaration of Conformity

Art. 47 + Annex V.

4

Compliance Calendar

Art. 111.

5

Conformity Sheet

Executive summary.

6

Quality Management System (QMS)

Art. 17.

7

Deployer Instructions

Document for the employer deploying your HR AI. Art. 13.

8

Evidence Checklist

Per Annex IV point.

9

Incident Template

Art. 73.

10

AI Literacy Programme

Art. 4.

11

Provider–Deployer Clauses

Chapter III.

12

Risk Committee Minutes

Art. 9.

Generated from your data, in your browser. No data leaves your device.

What you pay

🧾 AI ACT LEGAL OPINION FOR VIDEO INTERVIEW TOOL
€5,000–€15,000
2–4 months. Covers Art. 5 + Annex III classification.
✓ AICHECK
€249
12 documents. 45 min.

Provider and deployer: two layers

● LAYER 1

Annex IV technical documentation

12 docs. 45 min. €249. Provider obligation under Art. 11.

∅ LAYER 2

Deployer obligations under Art. 26

Your client (the employer) must ensure human oversight, inform workers, keep logs. AICheck generates the deployer instructions (Art. 13) they need from you. Deployer compliance is their operational responsibility.

We generate the provider documentation. Deployer compliance is their responsibility.

Enforcement regime

Article 99 of Regulation (EU) 2024/1689.

🇪🇺
Non-compliance with prohibited practices
€35M / 7%

Art. 99.3.

🇪🇺
Non-compliance with high-risk obligations
€15M / 3%

Art. 99.4. Includes failure to produce Art. 11 documentation.

🇪🇺
Supply of false or incomplete information
€7.5M / 1%

Art. 99.5.

Alternatives

AlternativeCostWhat you get
Read AESIA 62-page guideline + DIYFree + staff timeWeeks. Risk of structural gaps.
HR tech compliance consultancy€8,000–€20,0003–6 months.
Ignore documentation obligation€0 now€15M fine later
AICheck€24912 documents, 45 min

Providing HR AI to multiple enterprise clients across the EU?

If you need documentation for 5 or more systems, email us for volume pricing: hello@solidwaretools.com.

Request Volume Pricing
One-business-day response

What AICheck guarantees and what it does not

AICheck generates a document structured under Article 11 and Annex IV of Regulation (EU) 2024/1689 based on the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as provider of the AI system.

We guarantee that the document structure follows Article 11 and Annex IV of Regulation (EU) 2024/1689 and that the legal references cited are correct as of the latest verification date. We do not guarantee that a specific document will be accepted by a market surveillance authority in a specific case, nor by a commercial buyer in a procurement process.

AICheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.

Frequently asked questions — AI video interview tools and the AI Act

How do I know if my video interview tool is banned under Art. 5 or high-risk under Annex III?
Article 5.1(f) of Regulation (EU) 2024/1689 bans emotion recognition in workplace and education contexts. If your tool infers emotions from biometric data (facial expressions, voice tone), it is banned. If your tool analyses structured responses, transcript content, or task performance without emotion inference, it is Annex III.4(a) — high-risk and documentable. Use the free AICheck checker to verify your classification.
Does the prohibition on emotion recognition apply to sentiment analysis of text responses?
Art. 3(39) defines emotion recognition as inferring emotions from biometric data. Sentiment analysis of typed text responses does not use biometric data. However, sentiment analysis of voice recordings may qualify as biometric processing. The boundary is the data modality: biometric (voice, face) vs non-biometric (text).
We are pivoting away from facial analysis. Do we still need documentation?
If you remove the facial analysis component and your system only evaluates candidates through non-biometric means (structured response scoring, task completion), you move from potential Art. 5 prohibition to Annex III.4(a) high-risk classification. High-risk requires Annex IV documentation. Yes, you still need it.
Does recording candidate interviews for later human review involve AI?
If the recording is stored for a human to review without any AI processing, it is not an AI system. If any AI component processes the recording — transcription with NLP, speech pattern analysis, keyword extraction for scoring — that component is in scope.
Is this a subscription?
No. One-time payment. The licence includes 30 days of editing and 10 regenerations. The downloaded PDF is yours to keep.
Can I request a refund?
Under Article 16.m of Directive (EU) 2011/83 on consumer rights, by activating the licence you give express consent for the immediate generation of the digital content and waive the 14-day withdrawal period. Refunds are accepted only for verifiable reproducible technical failures.
What if the regulation changes?
If the regulation changes during the validity of your licence, you may regenerate the document with the updated version of the generator at no additional cost.
⚠️ Important notice: AICheck is a self-assessment documentation tool, not legal advice and not a third-party audit. The document under Article 11 and Annex IV of Regulation (EU) 2024/1689 is generated from your input data. You are responsible for the accuracy of the data you provide. AICheck does not replace a qualified professional assessment.

Your video interview AI is not banned — it is documentable. Generate the Annex IV dossier in 45 minutes.

Twelve documents. Annex IV fully structured. Regulation (EU) 2024/1689. Your data stays on your device. The ZIP you download is yours forever.

€249 one-time
12-document professional dossier · 45 minutes · No subscription · Browser-side
Generate Annex IV dossier — €249
✓ Last regulatory check: 28 April 2026 · No substantive changes detected · View history