The transport and logistics sector uses AI for everything from route optimisation to recruiting and staffing drivers, warehouse workers and technicians. When an AI system is used to screen candidates, allocate shifts or make personnel decisions, the activity falls under the EU AI Act (Regulation (EU) 2024/1689). This page sets out what that means for you as a deployer.
Your role: deployer of the AI system
The AI Act distinguishes between provider (Article 3(3)), who develops the system, and deployer (Article 3(4)), who uses it under its own authority. A transport company that buys a recruitment or staffing tool and applies it to its candidates and employees is a deployer.
You can, however, be reclassified as a provider under Article 25 if you put your name on the system, substantially change its intended purpose or make a substantial modification — and then you take on the provider's full obligations.
Recruitment and staffing AI is high-risk
AI for recruitment, selection, promotion, task allocation and termination is high-risk under Annex III, point 4, on employment. This also covers tools that decide who is assigned a shift or route based on a personal assessment. The classification triggers the deployer's obligations.
Deployer obligations (Article 26)
For high-risk AI, Article 26 requires, among other things, that you:
- follow the provider's instructions for use,
- ensure human oversight by competent and authorised staff,
- retain the system's logs (generally for at least six months),
- inform affected workers and their representatives before the system is put into use,
- monitor operation and report serious incidents.
In addition, Article 27 (fundamental rights impact assessment, FRIA), Article 50 (transparency) and Article 4 (AI literacy) may apply.
Dates
- 2 February 2025 — prohibitions (Article 5) and AI literacy (Article 4) apply.
- 2 August 2026 — transparency (Article 50) and high-risk deployer obligations (Annex III) apply.
The Digital Omnibus proposal to postpone parts of the high-risk rules to 2 December 2027 was approved by the European Parliament on 16 June 2026 but is not in force. Plan against 2 August 2026.
Penalties (Article 99)
- up to EUR 35m or 7% of global turnover for prohibited practices (Article 5),
- up to EUR 15m or 3% for breaching high-risk and transparency requirements,
- up to EUR 7.5m or 1% for incorrect information to authorities.
The higher of the amount and the percentage applies.
Note: vehicles and Annex I
The transport sector is also affected by Annex I of the AI Act, which covers AI as a safety component in products under EU product legislation (e.g. vehicles and their type-approval). This is a separate track from recruitment AI and is handled under Article 43(3) on sectoral conformity assessment. Read more on our page about product safety and AI in transport.
From requirement to evidence
PowerQuant delivers fixed-price compliance evidence (M1/M2/M3) documenting your deployer role, your Article 26 procedures and any Article 27 impact assessment — tailored to transport and logistics.
This page is general information about the AI Act and does not constitute legal advice.