Is my planning algorithm high-risk under the AI Act?
Adopted 2026-06-14 · ≈ 1 min read · 
edited by Dirk Baaijen
Software that drives rosters, trip planning or recruitment falls under Annex III of the AI Act and counts as high-risk. The heaviest duties apply from 2 Dec 2027; AI literacy already applies now.
Short answer: Probably yes. Algorithms that drive work rosters, trip planning, or recruitment and selection fall under Annex III (point 4) of the AI Act and therefore count as high-risk.
When is planning high-risk?
The AI Act (Regulation (EU) 2024/1689) classifies AI systems used for employment-related decisions as high-risk. This covers systems used in recruitment and selection, and in decisions about working conditions, task allocation, or steering work performance. A planning system that itself decides which driver gets which trip, or that assigns shifts and rosters, falls squarely into this category. A tool that merely aggregates data administratively, without affecting individual workers, sits outside the high-risk category. What matters is the actual function and the impact on people, not the product name.
Which deadlines apply?
The AI Act applies in phases. Prohibited practices and the AI literacy duty (Art. 4) have applied since 2 February 2025. Rules for general-purpose AI (GPAI) have applied since 2 August 2025. The Annex III high-risk obligations were formally set for 2 August 2026, but are being moved to 2 December 2027 via the Digital Omnibus. Transparency obligations (Art. 50) move to 2 December 2026. So you have time to get conformity in order, but the literacy duty is already in force.
Watch the adjacent rules too
Emotion recognition in the workplace — for example, driver monitoring that detects emotions — is a prohibited practice and is not allowed. A warehouse robot may also be a safety component (Annex I) in conjunction with the Machinery Regulation (EU) 2023/1230, which applies from January 2027. AI literacy applies to everyone who deploys AI: make sure your people understand how the system works and where its limits lie.
Read the main file: AI regulation for logistics and transport. Or take the Transport & Logistics scan.
Sources
- https://eur-lex.europa.eu/eli/reg/2024/1689/oj
Regulation (EU) 2024/1689 (AI Act); phased application 2025–2027.
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