Is AI Moving Too Fast for Compliance in STEM Hiring?

Our previous article explored AI liability in recruitment, highlighting the legal complexity under the EU AI Act and UK frameworks. This piece broadens the focus to a bigger issue facing STEM hiring: a rapidly fragmenting regulatory landscape with differing rules and timelines across jurisdictions. 

AI recruitment tools are now fully embedded, screening and ranking candidates at scale. In 2024 alone, they processed over 30 million applications and sparked hundreds of discrimination complaints. For HR and executive leaders, the question is whether compliance can keep pace.

The Compliance Landscape is Fragmenting

The UK and EU have moved from informal guidance to enforceable regulation on AI in hiring. The EU AI Act, effective from August 2026, treats recruitment AI as high-risk, requiring transparency, human oversight, bias testing, impact assessments, system registration, and detailed documentation, with heavy financial penalties for non-compliance.

The UK is taking a lighter, sector-based approach, but AI hiring tools must still meet Equality Act and UK GDPR requirements, alongside new ICO guidance and an upcoming statutory code on AI in employment.

For organisations recruiting STEM talent across both jurisdictions, this creates uneven compliance obligations and significant risk, including fines, discrimination claims, regulatory action, reputational harm, and loss of access to key talent pools.

What This Means for STEM Recruitment

The STEM sector presents unique compliance considerations in the UK and EU context. Engineering, manufacturing, and technology roles often involve:

• Cross-border hiring – UK–EU recruitment now involves fragmented GDPR and post-Brexit compliance requirements.
• AI screening at scale – High-volume technical screening faces increased scrutiny for bias under the EU AI Act and UK Equality Act.
• Third-party tools – Using RPOs or agencies does not remove liability for discrimination or regulatory action.
• Skills-based AI – Requires human oversight, bias testing, and (in the EU) fundamental rights impact assessments.

Building a Compliance Strategy 

We have created a comprehensive checklist to help you build a compliance strategy:

Map AI usage across recruitment

☐ Identify every AI tool used internally and by recruitment partners (ATS, CV screening, ranking, assessments, video interviews). 
☐ Flag EU-facing tools that qualify as high-risk under the EU AI Act.

Verify vendor compliance

☐ Obtain evidence of bias testing and human oversight. 
☐ Confirm data retention and logging practices. 
☐ Request EU AI Act conformity assessments and CE marking where applicable.

Implement meaningful human oversight

☐ Ensure trained recruiters review AI outputs.
☐ Confirm humans have authority to override AI decisions.
☐ Retain human decision-making for final hiring outcomes.

Establish documentation protocols

☐ Document how AI tools function and what data they use.
☐ Record which decisions AI influences and where human judgment applies.
☐ Retain EU AI Act documentation and logs for at least 10 years.

Conduct and record impact assessments

☐ Complete mandatory fundamental rights impact assessments for EU high-risk systems.
☐ Perform and document bias and impact assessments for UK operations.

Strengthen data governance

☐ Maintain records of recruitment data processing activities.
☐ Review UK–EU data transfer mechanisms post-Brexit.

Monitor regulatory developments

☐ Track EU AI Act implementation guidance.
☐ Monitor the ICO’s statutory code and enforcement activity.
☐ Update policies as requirements evolve.

Train hiring teams

☐ Provide training on AI capabilities, limitations, and bias risks.
☐ Document training to evidence compliance under EU and UK accountability requirements.

At Owen Daniels, we combine STEM recruitment expertise with robust compliance support, including payroll, workforce audit, IR35 navigation and right-to-work verification, to help you deploy AI and hire technical talent confidently and lawfully.

We help you build defensible, compliant processes with strong documentation, oversight and governance that align with both regulatory requirements and practical hiring needs. Whether it's vetting AI tools, managing payroll compliance globally, or auditing your workforce supply chain, we've got you covered.