Europe
European Union
Binding
National market surveillance authorities
AI Act classifies almost all HR AI as “high-risk.” Requires conformity assessments, risk management documentation, human oversight mechanisms and transparency to workers before deployment. Applies to any organisation deploying covered AI within the EU, regardless of where the tool was built.
High-risk employment provisions phasing in; full enforcement no later than December 2027
United Kingdom
Binding
Information Commissioner’s Office (ICO)
Data Use and Access Act 2025 (DUAA): impact assessments required for significant automated employment decisions; individuals retain right to human review and override. ICO codes of practice on AI hiring tools updated. Existing equality law already applies to AI-assisted decisions.
Lighter touch than EU AI Act but binding obligations in force
Germany & EU states
Binding
Works councils / labour courts
Works council co-determination rights when introducing AI-based HR tools. Employers must consult and agree with works councils before deploying AI in hiring or performance management. Applies in Germany, France, Spain, Italy, Austria and the Netherlands.
Operates alongside EU AI Act obligations; consent required before deployment
North America
USA — Federal
Retreating
DOJ / EEOC (limited)
No comprehensive federal AI employment law exists. The Trump administration is actively challenging state laws it regards as DEI-linked regulation. Colorado’s AI Act was the only state law named in a December 2025 executive order. A National AI Legislative Framework was published in March 2026 but is advisory only and imposes no obligations on employers.
Diverging sharply from the direction of most other major economies
Colorado (USA)
In dispute
State Attorney General
SB 24-205 (due 30 June 2026): written impact assessments; AI governance programme; bias monitoring; transparency notices to applicants; reporting of discriminatory outcomes to the Attorney General. Most comprehensive US state AI law to date.
Currently subject to federal lawsuit filed by DOJ and xAI; legal status uncertain
Illinois (USA)
Binding
Illinois Dept of Human Rights
Human Rights Act amendment (in force January 2026): prohibits use of AI that causes discriminatory effects on any protected class in hiring, promotion or termination; advance notice required when AI is used; applies to any employer with one or more employees in Illinois.
In force since 1 January 2026
New York City (USA)
Binding
NYC Dept of Consumer & Worker Protection
Local Law 144 (in force since July 2023): annual independent bias audit of automated employment decision tools (AEDTs); public summary of audit results required; candidate notice required when an AEDT is used in hiring or promotion.
First US jurisdiction to require bias audits; in force since 2023
California (USA)
Binding
CA Civil Rights Dept / CPPA
FEHA regulations (in force 2025–2026): AI tools causing discrimination on protected characteristics are unlawful; four-year record retention required. CCPA automated decision-making regulations (January 2026): risk assessments for sensitive data; opt-out rights for significant employment decisions including hiring, firing and performance evaluation.
Multiple overlapping frameworks; among the most detailed in the US
Canada
Partial
Federal / Provincial regulators
Ontario Working for Workers Act (in force January 2026): employers must disclose when AI is used in the hiring process. Federal Artificial Intelligence and Data Act (AIDA) pending: would regulate high-impact AI in employment nationwide. Existing federal privacy law (PIPEDA) applies to AI data processing.
Patchwork of provincial obligations; comprehensive federal law still pending
Asia-Pacific
South Korea
Binding
National AI Committee
AI Basic Act (in force January 2026): high-impact AI used in employment must allow meaningful human oversight and intervention at all times; transparency and labelling required; risk assessments must be documented; foreign companies must appoint a Korean local representative.
First comprehensive national AI law in Asia-Pacific; closest to EU AI Act in structure
China
Binding
Cyberspace Administration of China (CAC)
Algorithm Recommendation Regulation (in force March 2022): transparency in how algorithms process and recommend decisions. Mandatory labelling rules for AI-generated content. Security assessments required for publicly deployed AI models. Strictest active enforcement regime in APAC.
Multiple binding instruments; enforcement is active and penalties are meaningful
Japan
Promotional
AI Strategic Headquarters
AI Promotion Act (in force June 2025): a promotional framework encouraging responsible AI use; no penalties for non-compliance. Sector-specific guidelines expected throughout 2026. Existing Labour Standards Act and Personal Information Protection Act (APPI) continue to apply to AI-assisted employment decisions.
Innovation-first approach; penalties deliberately excluded from the framework
Singapore
Voluntary + pending
PDPC / Ministry of Manpower
AI Verify toolkit and Model AI Governance Framework: voluntary testing and accountability standards widely adopted. Workplace Fairness Act (passed 2025): Singapore’s first statutory anti-discrimination law; prohibits adverse employment decisions based on protected characteristics; mandatory grievance procedures required.
Workplace Fairness Act expected in force end-2027; AI Verify framework voluntary
Australia
Emerging
OAIC / Fair Work Commission
Mandatory AI guardrails for high-risk uses including employment are proposed but currently recommendatory only. Privacy Act amendment (in force December 2026): individuals gain the right to request information about substantially automated decisions affecting them. Existing anti-discrimination law already applies to AI-assisted hiring decisions.
Binding guardrails under development; watch for December 2026 Privacy Act changes
Latin America
Peru
Binding
Secretariat for Government & Digital Transformation (SGTD)
Law 31814 and Supreme Decree 115-2025-PCM (in force January 2026): AI used in recruitment, evaluation, hiring and dismissal is classified as high-risk; requires human oversight, algorithmic transparency and documented risk assessments before deployment. Sectoral compliance deadlines phase in from September 2026 (health, education, finance) to September 2029 (other sectors).
First binding AI framework in Latin America; modelled on OECD and EU principles
Chile
Partial / pending
Financial Market Commission / CMF
Personal Data Protection Law No. 21,719 (in force December 2026): individuals have the right to object to decisions based solely on automated processing, including employment decisions — closely aligned with GDPR Article 22. Separate comprehensive AI legislation under discussion.
Data protection rights binding from December 2026; broader AI law pending
Brazil / 
Colombia / 
Mexico
Draft
TBD
All three countries have AI legislation under active discussion. Brazil’s draft proposes a risk-based framework modelled on the EU AI Act, including the right to an explanation for AI-driven hiring decisions. Colombia and Mexico are at earlier stages of legislative development.
None yet enacted; watch for 2026–2027 developments in Brazil