AI Tools for HR: What Recruiting and People Teams Actually Use in 2026

AI tools for HR have moved well past the hype cycle. Recruiting teams use them to source and screen candidates. People ops teams use them to answer employee questions at 2 AM. Workforce planners use them to predict who's about to quit. The question isn't whether your HR department should use AI, it's which tools actually deliver results and which ones create more problems than they solve. This guide covers 10 tools across four HR functions, with honest assessments and a full section on the bias and compliance issues you can't afford to ignore.

For a broader look at AI tools across every business function, see our AI tools for business guide.

AI Tools for HR at a Glance

Here's the quick summary. Each tool is covered in detail below, grouped by what it actually does.

You'll notice most of these say "contact for pricing." That's the HR tech industry for you, nearly every vendor wants you on a demo call before showing a number. We've included ballpark figures where publicly available.

Before AI: How HR Teams Actually Hired

If you've worked in recruiting for more than five years, none of this will surprise you. But it's worth spelling out, because it explains exactly why these AI tools exist and what they're replacing.

Recruiters manually screened hundreds of resumes per opening, keyword-scanning for matches the same way a CTRL+F search works. A strong candidate with nontraditional experience? Filtered out because their resume didn't contain the right buzzwords. Interview scheduling was a ping-pong game of 5-10 emails per candidate, more if the hiring manager's calendar changed mid-thread. Job descriptions were written from scratch each time, or more realistically, copy-pasted from the last opening with a few details swapped out. Nobody tested whether the language in those descriptions was attracting or repelling certain candidate groups.

On the people ops side, employee engagement was measured by annual surveys. By the time those results got analyzed, presented to leadership, and turned into action items, the disengaged employees had already updated their LinkedIn profiles. Workforce planning was a spreadsheet exercise done once per year, usually by someone in finance who'd never spoken to a hiring manager about pipeline reality.

What changed isn't just speed, it's the nature of the work itself. AI matches candidates by skills and potential, not just resume keywords (that's what Eightfold does). Conversational AI schedules interviews in minutes via text instead of email chains (Paradox). Job descriptions get optimized for inclusion and conversion in real time, not after a bad quarter of diversity metrics (Textio). Employee sentiment is tracked continuously, flagging disengagement weeks before someone quits, not months after (Workday AI, Leena AI).

Here's the wrinkle that makes HR different from every other department adopting AI: regulatory scrutiny. NYC's Local Law 144, the EU AI Act, and a growing list of state-level legislation mean HR AI tools face direct legal accountability in a way that, say, an AI marketing copywriter doesn't. The old way had its biases too, human recruiters are demonstrably far from objective, but the difference now is that AI bias is auditable, measurable, and increasingly legally required to be tested. That's a genuinely new dynamic, and it shapes every tool recommendation in this guide.

Recruiting and Talent Acquisition

Recruiting is where HR teams adopted AI first, and it's where the tooling is most mature. These five tools cover the full recruiting pipeline: sourcing candidates, screening them, scheduling interviews, and evaluating fit.

Eightfold AI, Talent Intelligence for Enterprise

Eightfold AI is a talent intelligence platform built on deep learning that matches candidates to roles based on skills, not just resume keywords. It maps over 1.6 billion career profiles and 1.6 million skills to help you understand where candidates with the capabilities you need actually are.

What makes Eightfold different from a standard ATS? It doesn't just filter resumes by keyword matches. It infers skills from a candidate's career trajectory, identifies people who could do the job based on adjacent experience, and surfaces internal employees who might be ready for a role you were about to post externally.

• Skills-based candidate matching powered by deep learning, not keyword filters
• Internal mobility features that identify existing employees for open roles before you hire externally
• Diversity analytics and bias monitoring built into the matching algorithm
• Integrates with major ATS platforms (Workday, SAP SuccessFactors, Oracle)
• Pricing: Contact for pricing. Enterprise contracts typically start at $50,000+/year. Designed for organizations with 5,000+ employees.
• Best for: Large enterprises doing high-volume hiring who want to shift from resume screening to skills-based talent management

Limitation: This is enterprise-grade software with enterprise-grade complexity. If you're a 200-person company hiring 30 people a year, Eightfold is overkill. The implementation alone takes weeks, and the price point reflects the scale it's built for.

Paradox (Olivia), Conversational AI for High-Volume Hiring

Paradox built an AI assistant named Olivia that handles the entire top-of-funnel recruiting process through conversation. Candidates text Olivia (or chat via web, WhatsApp, or SMS), answer screening questions, schedule interviews, and get status updates, all without a recruiter touching anything.

The numbers are hard to argue with: Paradox reports a 99.78% positive candidate experience rating, 5x higher applicant conversion rates, and time-to-hire cut roughly in half. That tracks with what we see in the market, when you let candidates apply and schedule via text message instead of filling out a 45-minute application form, more of them finish the process.

• Conversational AI handling screening, scheduling, and candidate communication via SMS, WhatsApp, and web chat
• Candidates apply and book interviews in under five minutes
• Supports 100+ languages with automatic translation
• Pricing: Contact for pricing. Enterprise contracts typically use per-requisition or per-location pricing.
• Best for: Retail, hospitality, healthcare, logistics, any organization filling hundreds of hourly roles per month

Limitation: Paradox is designed for volume. If you're a tech company hiring 10 engineers a year, the investment doesn't make sense. This tool shines when you're processing thousands of applicants per month for frontline roles.

HireVue, AI-Powered Interview Assessment

HireVue combines video interviewing with AI-powered assessments. Candidates record responses to structured interview questions on their own time, and HireVue's AI evaluates their answers based on competency frameworks you define. Over a third of Fortune 100 companies use it.

A brief history lesson matters here: HireVue used to analyze facial expressions, which drew sharp criticism from civil rights organizations. They stopped that in 2021. Today the AI focuses on the content of what candidates say and how they perform on game-based skill assessments, not how they look while saying it. The platform conducts regular third-party bias audits and maintains an AI ethics board.

• On-demand video interviews candidates complete on their schedule
• AI assessment of language content (not facial expressions, that was dropped in 2021)
• Game-based skill assessments for cognitive and behavioral evaluation
• Structured interview consistency across all candidates
• Pricing: Contact for pricing. Typically enterprise licensing based on number of hires or assessments.
• Best for: Organizations that need structured, consistent candidate evaluation at scale, especially for early-career and campus hiring

Limitation: Candidate experience is polarizing. Some candidates appreciate the flexibility of recording on their own time. Others find it impersonal and uncomfortable talking to a camera with no human on the other side. If candidate experience is your top priority, pair HireVue with live interview stages.

Fetcher, AI Sourcing and Outreach Automation

Fetcher is an AI sourcing tool that identifies passive candidates and automates personalized outreach. What sets it apart from pure AI sourcing: Fetcher combines machine learning with a human curation layer. The AI identifies candidates from LinkedIn, Indeed, Stack Overflow, and other sources, then a human team reviews and refines the list before outreach begins.

That hybrid approach matters. Pure AI sourcing tends to surface the same candidates everyone else's AI is finding. The human review step catches false positives and adds judgment about culture fit and role nuance that algorithms still miss.

• AI-powered candidate sourcing across major platforms (LinkedIn, Indeed, Stack Overflow)
• Human-curated candidate lists, not just raw AI output
• Automated multi-step email outreach sequences
• Diversity sourcing with customizable demographic targets
• Full pipeline analytics and reporting
• Pricing: Plans start around $149/month for smaller teams. Custom pricing for enterprise.
• Best for: Recruiting teams and agencies sourcing passive candidates for hard-to-fill roles

Limitation: Outreach effectiveness depends heavily on your messaging. Fetcher automates the mechanics, but if your outreach emails read like generic templates, response rates will be low regardless of how good the sourcing is.

Textio, AI Job Description Optimization

Textio analyzes your job postings and recruiting communications in real time, flagging language that discourages diverse candidates from applying. It's trained on millions of actual hiring outcomes, not just linguistic theory, so it can predict which phrases attract broader candidate pools and which ones silently filter people out.

Here's a specific example of why this matters: Textio's data shows that job posts using phrases like "rockstar" or "ninja" attract 20-30% fewer female applicants. Posts using "competitive salary" instead of stating a range reduce applications across the board. These aren't hypothetical, they're patterns from millions of real job postings matched to real application data.

• Real-time language analysis and suggestions for job descriptions
• Bias detection trained on millions of actual hiring outcomes
• Recruiter messaging optimization (not just job posts)
• Performance review language analysis for equity
• Integrates with Greenhouse, Workday, and Outlook
• Pricing: Contact for pricing. Per-user licensing for recruiting teams.
• Best for: Talent acquisition teams focused on DEI and organizations under pressure to improve hiring diversity metrics

Limitation: Textio optimizes language, not your entire hiring funnel. If your interview process or compensation structure is the bottleneck for diversity, better job descriptions won't fix it alone.

Verdict: Eightfold AI leads for enterprise talent intelligence, and Paradox wins for high-volume hourly hiring. Fetcher is the pick for mid-market teams sourcing passive talent, and Textio is a must-have if DEI hiring outcomes are a strategic priority. HireVue fills the assessment gap but works best paired with human interview stages.

Employee Experience and HR Service Delivery

Recruiting gets the headlines, but HR teams spend the majority of their time answering employee questions, processing requests, and managing the day-to-day experience of people who already work for you.

Workday AI, The Platform Play

Workday AI (specifically Workday Illuminate) embeds AI features directly inside Workday's HCM platform. If your organization already runs on Workday, and many large enterprises do, this is the path of least resistance: no new vendor, no new integration, no new login for your team.

Workday's AI covers a broad range of HR workflows: skills-based talent matching through Skills Cloud, which automatically builds and maintains employee skill profiles from job history and learning activities. Career Hub gives employees a personalized space to explore learning paths, stretch projects, and internal roles that match their skills. Workforce planning features predict attrition risk and identify skills gaps before they become hiring emergencies.

• Skills Cloud: dynamic skills ontology that maps employee capabilities automatically
• Career Hub: personalized career development and internal mobility
• Workforce planning with attrition prediction and skills gap analysis
• AI recruiting agent for intelligent in-platform recommendations (launched 2025)
• Pricing: AI features included with Workday HCM subscriptions. Some advanced features may require additional modules.
• Best for: Organizations already on Workday who want AI embedded in their existing HR platform

Limitation: Only relevant if you're already a Workday customer. Migrating to Workday just for the AI features is a multi-year, multi-million-dollar project, that's not a realistic path to AI adoption.

Leena AI, Autonomous HR Service Desk

Leena AI automates employee-facing HR services: answering policy questions, processing leave requests, handling onboarding tasks, and routing complex issues to the right HR specialist. Think of it as an AI help desk specifically built for HR.

The practical impact? Your HR team stops answering the same 50 questions every day ("How many vacation days do I have left?" "What's the bereavement leave policy?" "How do I update my direct deposit?"). Leena AI reports 70%+ automation rates on routine HR queries and 90%+ ticket resolution rates.

• AI virtual assistant for employee policy questions and requests
• Case management that routes complex issues to the right HR specialist
• Document management and policy automation
• Onboarding workflow automation
• Analytics dashboard tracking resolution rates and employee satisfaction
• Pricing: Contact for pricing. Enterprise licensing based on employee count.
• Best for: Organizations with 1,000+ employees where HR teams are overwhelmed by repetitive, routine questions

Limitation: Leena AI is only as good as the knowledge base you feed it. If your HR policies are scattered across 47 different Google Docs with conflicting information, the AI will surface those contradictions. Clean up your documentation first.

Verdict: Workday AI is the obvious choice if you're already on Workday, zero procurement friction. Leena AI is the pick for HR service automation regardless of your HCM platform, especially if your team spends too much time answering routine questions.

People Analytics and Workforce Intelligence

You can't improve what you don't measure. People analytics tools turn raw HR data into decisions: who's likely to leave, where your skills gaps are, whether your diversity initiatives are working, and what's driving employee engagement scores up or down.

Visier, The Analytics Leader

Visier is the market leader in people analytics. It pulls data from your HRIS, ATS, payroll system, and engagement surveys, then visualizes it through 50+ pre-built metrics and reports covering workforce composition, performance trends, retention risk, and diversity.

What makes Visier stand out isn't just dashboards, it's the predictive layer. Machine learning models forecast attrition risk, identify flight-risk employees before they start interviewing elsewhere, and model the financial impact of different workforce scenarios. The AI assistant, Vee, lets HR leaders and managers ask workforce questions in plain English and get instant answers backed by data.

• 50+ pre-built analytics metrics and reports
• Predictive analytics for attrition, skills gaps, and workforce planning
• Vee: AI digital assistant for natural-language workforce queries
• Manager Agent: real-time data and nudges delivered inside Slack and Teams
• Integrates with Workday, SAP, Oracle, ADP, and most major HRIS platforms
• Pricing: Contact for pricing. Tiered based on employee count and modules.
• Best for: CHROs and people analytics teams who need data-driven workforce decisions, not just reports, but predictions and recommendations

Limitation: Visier requires clean, connected data to deliver value. If your HR data lives in disconnected systems with inconsistent formats, plan for a data integration project before you see meaningful analytics. The tool is powerful, but garbage in still means garbage out.

Verdict: Visier is the clear leader for people analytics. If your organization is making workforce decisions based on gut instinct or lagging indicators, Visier turns that into predictive, data-backed strategy.

Talent CRM and Workforce Planning

These tools operate at a longer time horizon. Instead of filling today's open requisitions, they help you build talent pipelines, plan for skills your organization will need in 12-24 months, and treat talent management as a continuous process rather than a fire drill.

Phenom, The All-in-One Talent Experience

Phenom is a talent experience platform that covers the full spectrum: career sites, chatbots, CRM, screening, interview scheduling, internal mobility, and workforce intelligence, all in one connected platform. It's the broadest tool on this list in terms of feature coverage.

Phenom's AI-powered career sites personalize the job search experience for each visitor, surfacing relevant roles based on their skills and behavior. The chatbot handles candidate questions and screening. Campaigns automate personalized multi-step outreach. And on the employee side, a talent marketplace connects internal candidates with open roles, gigs, and mentoring opportunities.

• AI-personalized career site experiences
• Conversational chatbot for candidate screening and scheduling
• Talent CRM with multi-step automated campaigns
• Internal talent marketplace for employee mobility
• Workforce intelligence and skills analytics
• Pricing: Contact for pricing. Enterprise licensing, typically mid-five to six figures annually.
• Best for: Mid-to-large enterprises that want one platform covering recruiting, internal mobility, and talent marketing

Limitation: Breadth comes at the cost of depth. Phenom does many things well, but if you need best-in-class capability in one specific area (say, sourcing or analytics), a specialist tool will likely outperform it in that niche.

Beamery, Talent CRM and Strategic Workforce Planning

Beamery focuses on two things: building long-term talent pipelines (talent CRM) and strategic workforce planning. The idea is that hiring success depends on relationships built before a role opens, not scrambling to source candidates after a requisition drops.

Beamery's AI Talent Match connects candidates to roles based on skills, not just job titles. The workforce planning module gives real-time intelligence on skills supply and demand, delivered inside Slack and Teams where managers actually work. The platform even nudges managers to refine hiring requirements or consider adjacent skills when filling roles.

• AI-powered talent CRM with skills-based matching
• Real-time workforce planning with skills supply and demand intelligence
• Manager nudges delivered inside Slack and Microsoft Teams
• Candidate pipeline nurturing with automated engagement workflows
• Pricing: Contact for pricing. Enterprise contracts.
• Best for: Organizations that take a strategic, long-term approach to talent, building pipelines 6-12 months before roles open

Limitation: Beamery requires organizational commitment to proactive talent management. If your company only starts recruiting after someone gives notice, the CRM pipeline approach won't get used, and you'll be paying for capabilities that sit idle.

Verdict: Phenom wins for breadth, it's the closest thing to a one-platform solution for talent acquisition and management. Beamery wins for strategic depth, especially if workforce planning and long-term pipeline building are your priorities.

AI Hiring Bias and Regulatory Compliance

This section isn't optional reading. If you're deploying any AI tool that touches hiring decisions, you're operating in an increasingly regulated space. Two regulations matter most right now.

NYC Local Law 144: The First Mandatory AI Hiring Audit

New York City's Local Law 144, in effect since July 2023, requires any employer using an "automated employment decision tool" (AEDT) in NYC to conduct an independent bias audit annually. You must publish the audit results on your website and notify candidates that an AI tool is evaluating them.

Here's what makes this urgent in 2026: a December 2025 audit by the NY State Comptroller found that enforcement has been "ineffective." Seventy-five percent of test calls to NYC's 311 hotline about AEDT issues were misrouted. The agency found just one non-compliance case among 32 companies surveyed, while auditors identified at least 17 potential violations in the same group. The result? The enforcement agency has agreed to overhaul its approach, meaning companies that have been skating by on weak enforcement should expect that window to close.

What you need to do:

• Identify every AI tool touching hiring decisions for NYC candidates
• Commission an annual independent bias audit from a qualified third party
• Publish audit results on your company website
• Notify candidates that AI is being used in their evaluation

EU AI Act: High-Risk Classification for All HR AI

The EU AI Act classifies all AI systems used in recruitment, hiring, and HR decision-making as "high-risk." That means mandatory documentation, human oversight requirements, bias testing, and transparency obligations.

Key dates: prohibited AI practices (like emotion recognition in workplaces) became enforceable in February 2025. The full compliance requirements for high-risk HR AI systems become enforceable on August 2, 2026. If your company hires in the EU, evaluates EU-based workers, or deploys HR tools used by EU teams, the Act applies to you, even if your company is headquartered outside the EU.

What you need to do:

• Audit which HR AI tools you use and whether they qualify as high-risk
• Ensure adequate human oversight exists for every AI-assisted hiring decision
• Prepare documentation of training data, testing procedures, and bias mitigation measures
• Establish transparency measures so candidates know AI is being used

Practical Bias Mitigation

Beyond regulatory compliance, here's what responsible AI deployment looks like in practice:

1. Never let AI make the final decision. AI should shortlist, score, or recommend, humans should decide. Every tool on this list is designed to assist, not replace, human judgment.
2. Audit outcomes quarterly, not just annually. Check whether AI-screened candidate pools differ meaningfully by gender, race, age, or disability status. Don't wait for the annual compliance audit to discover a problem.
3. Test with your own data. Vendor bias audits use the vendor's test data. Run the tool against your actual applicant pool and measure whether outcomes are equitable across demographic groups.
4. Document everything. Which tool, which version, what criteria, what override rate. When regulators ask, and they will, you need a paper trail.

Verdict: Compliance isn't optional, and it's getting stricter. NYC Local Law 144 enforcement is ramping up in 2026, and the EU AI Act's high-risk requirements hit in August. Budget for annual bias audits and human oversight processes alongside every HR AI tool purchase.

How to Choose the Right AI HR Tool

With 10 tools covered, here's a decision framework to narrow it down.

And here's the decision path in prose:

Start with the problem. Are you drowning in applications for hourly roles? Paradox. Struggling to source passive engineering candidates? Fetcher. Can't get workforce data out of spreadsheets? Visier. Already on Workday and wondering if there's more? Turn on Workday AI.

Check your scale. Eightfold, Phenom, and Beamery are enterprise plays, they don't make economic sense below 1,000-2,000 employees. Fetcher and Textio are accessible to mid-market teams. Leena AI hits the sweet spot for organizations with 1,000+ employees.

Then check compliance. Before you sign anything, ask the vendor: Do you support Local Law 144 bias audits? What's your EU AI Act roadmap? Can you provide documentation for high-risk classification? If the vendor can't answer these questions clearly, that's a red flag.

When Off-the-Shelf Tools Don't Fit: Building Custom HR AI

Every tool on this list solves a general problem. But some HR teams have workflows specific enough that a vendor product doesn't quite cover them, a proprietary screening rubric, an internal mobility matching process tied to a custom competency model, or an onboarding flow that pulls data from five different systems no vendor has pre-built connectors for.

At Techsy, we've worked with HR and people ops teams to build custom AI agents that sit on top of their existing ATS and HRIS infrastructure. That includes agents for proprietary hiring workflows where the screening logic is too nuanced for a standard vendor configuration, internal mobility matching that connects employee skill profiles across disconnected systems, and integration layers that tie tools like Eightfold or Paradox into homegrown platforms the vendor doesn't natively support. If your team's bottleneck is less about finding the right product and more about making AI work with the systems you already have, we should talk.

FAQ

What are the best AI recruiting tools in 2026?

For enterprise talent intelligence, Eightfold AI leads with deep-learning skills matching across 1.6 billion profiles. For high-volume hourly hiring, Paradox (Olivia) cuts time-to-hire in half through conversational AI. Fetcher handles passive sourcing with a human-curated approach, and Textio optimizes job descriptions for inclusive language. Your best fit depends on what type of hiring you do most.

Is AI hiring legal?

Yes, but increasingly regulated. NYC's Local Law 144 requires annual independent bias audits for any AI tool used in hiring decisions for NYC candidates, plus candidate notification. The EU AI Act classifies all recruitment AI as "high-risk" with full compliance requirements enforceable from August 2026. Illinois and Maryland have additional disclosure requirements. The trend is clear: more regulation, not less.

Do AI recruiting tools have bias problems?

They can. AI models trained on historical hiring data can perpetuate existing biases, if your past hiring skewed toward certain demographics, the AI may replicate that pattern. HireVue dropped facial expression analysis in 2021 after bias concerns. Reputable tools (Eightfold, Textio, HireVue) now conduct regular third-party bias audits and build bias penalties into their algorithms. The key is ongoing monitoring with your own data, not just trusting the vendor's audit.

How much do AI HR tools cost?

Ranges vary wildly. Fetcher starts around $149/month for small teams. Textio, Paradox, HireVue, and Leena AI use enterprise pricing that typically requires a sales conversation. Eightfold, Phenom, and Beamery run $50,000-$200,000+/year for enterprise contracts. Workday AI is included if you're already paying for Workday HCM. Budget for implementation costs (typically 15-25% of the first-year license) on top of the subscription.

Can AI replace human recruiters?

No, and the best tools aren't trying to. AI handles the high-volume, repetitive parts of recruiting: sourcing candidates, screening applications against criteria, scheduling interviews, and answering FAQ-level questions. The judgment calls, evaluating culture fit, selling the opportunity to a passive candidate, navigating a complex offer negotiation, still require humans. Think of it as AI handling the 80% of recruiting tasks that are process, freeing recruiters for the 20% that's relationship and judgment.

What is NYC Local Law 144 and does it apply to my company?

Local Law 144 requires employers using automated employment decision tools in New York City to conduct annual independent bias audits, publish the results, and notify candidates. It applies to any employer evaluating candidates for positions based in NYC, even if your company is headquartered elsewhere. A December 2025 state comptroller audit found enforcement has been weak, but the enforcement agency has committed to a stricter approach in 2026.

How does the EU AI Act affect HR technology?

The EU AI Act classifies all AI used in recruitment, hiring decisions, and employment management as "high-risk." This requires documentation of training data, human oversight for all AI-assisted decisions, bias testing, and transparency to candidates. The full requirements become enforceable on August 2, 2026. It applies to any company that uses AI outputs affecting EU workers or candidates, regardless of where the company is headquartered.

What's the difference between a talent intelligence platform and an ATS?

An ATS (Applicant Tracking System) manages applications after candidates apply, tracking them through stages, scheduling interviews, storing resumes. A talent intelligence platform like Eightfold AI goes further: it uses AI to understand skills across your entire talent ecosystem (external candidates, internal employees, alumni), predicts candidate-role fit based on career trajectories, and identifies internal mobility opportunities. An ATS is a filing system. A talent intelligence platform is a recommendation engine.

Final Verdict

Three things to remember:

1. Start with one tool, not five. Pick the function where your team spends the most time on repetitive work. That's where AI ROI shows up fastest.
2. Budget for compliance alongside software. Every AI hiring tool purchase should include a line item for annual bias audits and regulatory documentation. It's not optional spend anymore.
3. AI assists, humans decide. The tools on this list are genuinely powerful, but the moment you remove human oversight from hiring decisions, you're both ethically exposed and legally vulnerable.

The HR teams getting the most from AI aren't the ones buying every tool on this list. They're the ones picking the right tool for their specific bottleneck, implementing it properly, auditing it regularly, and keeping a human in the loop.

Sources

• Eightfold AI - Talent Intelligence Platform
• Paradox - Conversational Hiring Software
• HireVue - AI-Powered Hiring
• Textio - Augmented Writing for HR
• Phenom - Intelligent Talent Experience
• Beamery - Talent Lifecycle Management
• Leena AI - Enterprise HR Automation
• Fetcher - AI Recruiting Automation
• Visier - People Analytics Platform
• Workday - AI for HCM
• NYC Local Law 144 - Automated Employment Decision Tools
• NY State Comptroller Audit on Local Law 144 Enforcement
• DLA Piper - Critical Audit of NYC's AI Hiring Law
• EU AI Act - High-Risk AI Systems Annex III