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AI Governance · 8 min read

The FRIA Trap: Why Your Vendor’s AI Act Compliance Won’t Save You

Walk into almost any talent acquisition function in Europe right now and you will find the same conversation. The AI vendor has sent over a thick PDF. It is titled something like “EU AI Act Conformity Assessment” or “Act-Ready Compliance Kit.” The procurement team has reviewed it. Legal has glanced at it. The TA director has filed it. Everyone agrees: we are covered.

The numbers suggest this is the dominant mood. Gartner’s October 2025 survey found 68% of European enterprises now use AI for talent acquisition, up from 42% the year before, with high-risk systems like predictive hiring platforms present in 45% of those deployments. Deloitte’s 2026 Global Human Capital Trends reports 52% of TA leaders plan further high-risk AI deployments by mid-2026. And per Forrester’s February 2026 poll of 300 TA executives, 73% of HR leaders assume their vendor’s compliance work is sufficient.

It is not. And the gap between what vendors deliver and what deployers are legally required to produce is the single most expensive misunderstanding in HR technology right now.

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