COMPLIPATHDOC complipath.io/example-assessmentRENDERED 2026-08-23ENGINE 2026-08-09.1CORPUS 2024/1689 + 2026/1744 + Commission guidelines
Example assessment

Kestrel Applicant Ranking (test)

An example system, run through the real engine. Kestrel Applicant Ranking (test) is not a customer and not a real company. The system is invented; the engine, the rules, the citations and everything below are not. What it does: Ranks written job applications against the stated requirements of each open role, and returns an ordered shortlist to the hiring manager. Built in-house on an open-weights model, fine-tuned on our own historical hiring data. Used for roles advertised in Sweden, Germany and the Netherlands.

risk level: high · confirmed 2026-08-17 · engine 2026-08-17.2 · fetched 2026-08-23

This assessment was recorded on 17 August 2026. What it rested on is stored and unchanged: the provisions engaged, the engine version, and the source texts those were derived from. The citations below are shown in the notation the Regulation uses today — naming a provision differently does not change which provision it is.

This is a classification decision record. It carries the answers as they were given, the engine version that decided them, the version of the law it was decided against, the outcome with its reasoning, and the provisions the engine declined to reach a conclusion on.

The verdict, with its reasoning

You answered that the system is used for the recruitment or selection of people — in particular to place targeted job advertisements, to analyse and filter job applications, and to evaluate candidates. Article 6(3) lets a provider conclude that a system referred to in Annex III is not high-risk. That conclusion is the provider's and is documented against the system — Complipath does not reach it from your answers. Fine-tuning a third-party model can make you a provider under Article 25(1)(b).
citation: point 4(a) of Annex III · assessed 2026-08-17 · contested: false · stage: confirmed

Record not yet complete

What is still open, as the route reports it:

record complete: false

Complete against what this workspace asks for. It is not a statement that this system complies with the Regulation.

What the engine did not decide

These provisions turn on a judgement the engine does not make. Each one is listed with what it rests on, and it is a person who reaches the conclusion.

Article 6(3)
Article 6(3) lets a provider conclude that a system referred to in Annex III is not high-risk. That conclusion is the provider's and is documented against the system — Complipath does not reach it from your answers.
Same system, two dates

Eight of this system's obligations apply from 2 December 2027; the registration duty applies from 2 August 2026. Both dates are derived, not chosen: Article 113, third paragraph, point (c), as amended by Regulation (EU) 2026/1744, defers Chapter III, Sections 1, 2 and 3 — and Article 49 sits in Section 5, which point (c) does not defer, so registration keeps the general date in Article 113, second paragraph. One system, two clocks, both read off which provision is deferred and which is not. Every date in one table.

Every obligation, with its status

All 9 as the engine derived them — including the statuses that look bad. Each carries the engine's guidance on what evidence answers it.

Risk management system
Article 9 · not started
from 2 December 2027

Produce a risk log, minutes of the reviews, and a list naming who owns each mitigation.

Data and data governance
Article 10 · not started
from 2 December 2027

Produce a description of the datasets and a record of where they came from — and, if you carry out bias detection, its results.

Technical documentation
Article 11 / Annex IV · not started
from 2 December 2027

Produce the technical documentation itself. The documentation workspace drafts some of its sections; the Annex IV points it does not reach are yours to add.

Record-keeping
Article 12 · not started
from 2 December 2027

Produce a retention policy and a sample export of the logs.

Transparency and provision of information to deployers
Article 13 · not started
from 2 December 2027

Produce the instructions for use that go to whoever deploys the system, and keep the version you handed over.

Human oversight
Article 14 · not started
from 2 December 2027

Produce an escalation procedure and a training record for the people assigned to oversee the system.

Accuracy, robustness and cybersecurity
Article 15 · not started
from 2 December 2027

Produce an accuracy test report, a summary of the penetration testing, and the monitoring alerts you keep.

Quality management system
Article 17 · not started
from 2 December 2027

Produce a quality management policy, a responsibility matrix and an internal audit plan.

Registration (EU database)
Article 49 · not started
from 2 August 2026

Produce the confirmation of registration in the EU database and the data set filed under Annex VIII.

requires Annex IV documentation: true

What drove the classification

The factors behind the verdict, as the engine recorded them.

You answered that the system is used for the recruitment or selection of people — in particular to place targeted job advertisements, to analyse and filter job applications, and to evaluate candidates.
point 4(a) of Annex III
Article 6(3) lets a provider conclude that a system referred to in Annex III is not high-risk. That conclusion is the provider's and is documented against the system — Complipath does not reach it from your answers.
Article 6(3)
Fine-tuning a third-party model can make you a provider under Article 25(1)(b).
Article 25(1)(b)

What changed in the law since this assessment

The corpus comparison — the thing an assessment without a date cannot tell you.

Amended since the assessment
Provisions this run touches whose text Regulation (EU) 2026/1744 changed.
Article 10 (points 9) · Article 11 / Annex IV (points 10) · Article 17 (points 11)
Not amended
Checked and unchanged — the comparison says so; nobody assumed it.
point 4(a) of Annex III · Article 6(3) · Article 25(1)(b) · Article 9 · Article 12 · Article 13 · Article 14 · Article 15 · Article 49

corpus comparison run 23 August 2026, 17:55 UTC

What was answered

The raw answer set, in the engine's own field names — the assessment works from what it was told, and this is what it was told.

type: fine_tuned_third_party
art5_review: ["none_of_these"]
art50_content: []
law_functions: []
art50_exposure: neither
emotion_context: null
annex_categories: ["employment"]
automated_action: false
credit_functions: []
human_can_overrule: false
affects_individuals: true
biometric_functions: []
sensitive_inference: null
art5_sexual_material: null
employment_functions: ["recruitment_selection"]
scraped_face_database: null
safety_component_endangers: null
criminal_risk_solely_profiling: null
realtime_public_law_enforcement: null

Who answered, and when

Provenance is part of the assessment: a recorded answer has an answerer.

The route served null for this field — nothing is recorded here, and nothing is inferred from that.

Documentation state

The Annex IV workspace as it stands — including what is not reviewed.

overview
reviewed
data_description
not reviewed
risks_mitigations
not reviewed
human_oversight
not reviewed

What this run covers

The scope the engine states for itself.

This assessment covers Annex III high-risk classification, Article 50 transparency obligations, and Article 5 prohibited practices. The fact-based prohibitions in Article 5(1)(d)–(h) produce an outcome. The judgement-based prohibitions in Article 5(1)(a)–(c) are flagged for legal review — whether they apply is a judgement Complipath does not make.
Annex I not assessed: This assessment does not cover Article 6(1). Under that provision an AI system is high-risk only where both conditions are met: it is intended to be used as a safety component of a product, or is itself a product, covered by the Union harmonisation legislation listed in Annex I; and that product is required to undergo a third-party conformity assessment. If that describes this system, it is not classified here and needs a separate assessment. Article 6(1) applies from 2 August 2028.

This page is rendered from the engine's own output, fetched from the app at every build — never written by hand. Corpus: Classification derived from Regulation (EU) 2024/1689, Regulation (EU) 2026/1744. Provisions in that corpus that this assessment does not detect: Article 6(1) — Annex I high-risk (applies from 2 August 2028).. Where the engine stops and why is in what this check can and cannot decide; the classification method it follows is the five-step order.

Complipath

Complipath is EU AI Act compliance software for AI-heavy software companies without a compliance team — an AI system register, deterministic risk classification, the obligations that follow, and the evidence behind every decision.

Complipath is built by Yobel Tzegai in Gothenburg, Sweden.

Complipath provides legal information, not legal advice. Every guide cites its source on EUR-Lex — Regulation (EU) 2024/1689, and Regulation (EU) 2026/1744 where that has amended it; where the law is still settling, the guide says so.

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