What Bulgarian Labour Market Data Reveals: Why the EU AI Act Makes HR a Strategic Function

Artificial intelligence has already fundamentally reshaped how organisations source, assess, hire, retain and offboard talent.

From drafting job specifications and screening applications to parsing CVs, conducting automated video interviews, and handling candidate communication, AI is fast becoming embedded in daily HR workflows.

The question is no longer whether AI has a place in recruitment. It is already here.

The critical question is: how prepared are organisations to deploy AI transparently, ethically, and in full compliance with emerging regulations?

To find out, New Career conducted a series of polls targeting the LinkedIn professional community in Bulgaria. The findings highlight an operational gap that every corporate leadership team must address.

The Data Speaks Clearly: Candidates Rarely Know When AI Is Involved

67% of respondents reported that they have never been notified that their data was being processed by AI during a job application.
Only 12% stated they had received such notices on rare occasions.

This reveals a striking paradox:

On one hand, employers are accelerating their investments in automation and AI tools.
On the other hand, candidates are kept largely uninformed about how these technologies are applied.

This disconnect creates a sharp divide between the operational reality of recruitment and candidate perception, ultimately placing job seekers at a distinct information disadvantage.

Half of All Candidates Suspect AI Evaluates Them Unannounced

Perhaps the most telling finding: 50% of respondents believe it is entirely possible they have undergone an AI-driven evaluation without ever knowing it.

This sentiment should not be mistaken for tech scepticism. Rather, it reflects a justified lack of confidence in employer transparency.

When candidates do not know:

who or what is evaluating their application,
what criteria are being applied,
what data points are being analysed, or
whether a human recruiter reviews the final output,

they naturally question whether the process is fair, objective, and non-discriminatory. In recruitment, candidate trust is the cornerstone of employer brand reputation.

A Flawed Corporate Assumption

Many employers avoid disclosing their use of AI out of fear that it will alienate applicants. The survey data disproves this premise.

When asked how they would respond if an employer openly disclosed the use of AI in the hiring process:

40% stated they would be completely comfortable and would proceed with the process;
28% regarded the information as immaterial to their decision;
15% would seek additional details before proceeding;
Only 17% stated they would withdraw their application.

In short, nearly 70% of respondents have no fundamental objection to AI or automated agents in recruitment. The problem is not the technology - it is the lack of transparency.

Organisations that conceal AI adoption make an unnecessary strategic misstep by hiding processes that most candidates would accept if communicated openly and clearly.

The EU Artificial Intelligence Act Is Redefining HR’s Strategic Mandate

Until recently, AI adoption was treated almost exclusively as an IT and operational initiative. Today, it sits at the high-stakes intersection of:

Human resources
Legal compliance
Data privacy
Enterprise risk management
Corporate reputation

It is essential to understand a critical distinction that organisations frequently overlook:

The EU AI Act and the GDPR Are Not the Same
The GDPR governs the processing of personal data.

The EU AI Act regulates the deployment, governance, and safety of AI systems themselves.

In recruitment, both frameworks apply simultaneously, but they address entirely different risks. An employer may be fully GDPR-compliant yet fundamentally unprepared for the operational mandates of the EU AI Act—and vice versa. Going forward, forward-looking organisations must treat data privacy and AI compliance as interdependent disciplines.

Not All HR AI Carries the Same Risk Profile

A common misconception is that every AI application in HR falls under heavy regulatory scrutiny. In reality, the regulatory burden depends on the specific use case:

Lower-Risk Use Cases:

When HR teams leverage generative AI for supportive administrative tasks such as:

drafting job postings,
summarising interview notes, or
generating interview question templates,

the compliance risk remains low.

High-Risk Use Cases:

The regulatory bar rises dramatically under the EU AI Act when AI systems are deployed to:

screen, rank, and filter candidates,
evaluate suitability or assess personality traits,
directly influence hiring decisions,
inform promotion, allocation, or termination decisions, or
monitor and evaluate employee performance.

These applications fall directly into the High-Risk category under the EU AI Act because they directly impact an individual’s livelihood and career opportunities. Consequently, they require strict safeguards, rigorous documentation, and verifiable human oversight.

The Next Major Challenge: AI Governance

In our advisory practice, we frequently encounter organisations that have already deployed AI tools across their talent acquisition workflows but cannot answer foundational governance questions:

Where exactly is AI being used across our organisation?
Which business decisions does it inform or automate?
What specific candidate or employee data is fed into these models?
Who holds ultimate accountability for the system's output?
How do we audit the system for bias and algorithmic drift?
How would we respond if an applicant requested an explanation of an automated decision?

This is where AI Governance becomes critical. It is not merely an IT safeguard; it is a business framework encompassing explicit policies, clear lines of accountability, and enforceable internal controls.

The First Step Is Not Compliance. It Is an AI Audit

Many organisations rush into compliance policies without first mapping their existing technical footprint. Before building a governance framework, you must establish an accurate baseline of your current operations.

A rigorous HR AI audit examines five dimensions:

Technology: What AI, machine-learning, and automated tools are currently deployed across your HR tech stack?
Processes: At which stages of sourcing, screening, selection, and performance review do these tools operate?
Data: What personal data, resumes, video streams, or assessment scores are processed by these systems?
Risk: What legal, operational, and reputational liabilities could arise for candidates and current employees?
Control: Where is human oversight applied, and who makes the final hiring determination?

For many leadership teams, this audit produces an immediate wake-up call: AI is often embedded far more widely across line-management workflows than executive leadership realizes.

What Does an AI-Ready Organisation Look Like?

An organisation prepared for the regulatory and talent demands of the modern market can confidently demonstrate that:

It maintains an accurate inventory of all AI systems in use.
It understands precisely which hiring decisions are augmented by technology.
It maintains meaningful human oversight ("human-in-the-loop") across all critical junctures.
It communicates transparently with candidates regarding AI usage.
It routinely conducts bias and risk assessments.
It contracts exclusively with HR tech vendors who demonstrate verifiable regulatory compliance.
Its HR business partners and hiring managers are trained in ethical AI standards.
It operates under clear, documented internal AI policies.

The Real Competitive Advantage Will Not Be the Technology Itself

Within the next few years, virtually every company will utilise AI in some capacity. Technology alone will no longer provide a sustainable market differentiator.

The real competitive advantage will belong to organisations that can prove they use technology responsibly:

Candidates will choose employers they trust.
Corporate clients and investors will partner with businesses that proactively manage regulatory risk.
Regulators will enforce auditable, demonstrable transparency.
Employees will demand assurance that their career progression is not governed by an unvetted black box.

Conclusion

Our market data points to an unambiguous reality: candidates do not reject AI in recruitment.

What they expect is clarity:

To know when it is deployed;
To understand how it influences decisions;
To know how their data is safeguarded; and
To be assured that a human professional remains accountable for the outcome.

This is where AI efficiency, trust, and effective recruitment converge. The coming years will not be won by the companies that deploy the most algorithms, but by those that manage them with the highest degree of transparency, ethics, and regulatory competence.

This is no longer merely a technology challenge—it is a core leadership mandate.

About the Author

Nikolay Nikolov

Managing Director & Co-Founder, New Career

Board Member, Bulgarian Association for People Management (BAPM)

Chairman, Bulgarian Confederation on Employment (BCE)

At New Career, we believe that AI literacy and compliance will become non-negotiable competencies for the HR profession. We actively partner with international and local organisations to integrate recruitment technologies that satisfy strict regulatory frameworks while safeguarding candidate rights and data integrity. True AI readiness requires HR, Legal, Compliance, and executive leadership to operate as one unified team.

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Survey: Candidates Are Open to AI in Recruitment. The Real Concern Is Lack of Transparency