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Key Dates for HR in Ireland under the EU AI Act
Published on: 10/02/2025
Issues Covered:
Artificial Intelligence
Article Authors The main content of this article was provided by the following authors.
Barry Phillips Chairperson, Legal Island
Barry Phillips Chairperson, Legal Island
Barry Phillips Resized
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Barry Phillips (CEO) BEM founded Legal Island in 1998. Since then, the company has become the leading workplace compliance training company in the island of Ireland. He was awarded a British Empire Medal in the New Year’s Honours List 2020 for services to employment and equality.

Barry is a qualified barrister, coach and meditator and a regular speaker both here and abroad. He also volunteers as mentor to aspiring law students on the Migrant Leaders Programme.

Barry is an author, releasing his latest book titled 'Mastering Small Business Employee Engagement: 30 Quick Wins & HR Hacks from an IIP Platinum Employer' in 2020 along with Legal Island MD Jayne Gallagher.

Barry has worked at the European Parliament, the European Court of Human Rights and the International Labour Organisation in Geneva before qualifying as a lawyer in 1993.

He has travelled extensively and lived in a total of eight different countries considering himself to be a global citizen first, a European second and British/Irish citizen last of all. His guiding mantra in life is “Never react but respond. Get curious not furious.”

Barry is an Ironman and lists Russian language and wild camping as his favourite pastimes.

The 2nd February 2025 was the first milestone date for implementation of some of the provisions of the EU AI Act and there are more to follow.

This table sets out the most important dates for HR and recommended actions.

 

Date 

 

Milestone 

 

Action Points for HR 

 

12 July 2024 

 

Publication in the Official Journal of the European Union 

 

 

1 August 2024 

 

EU AI Act enters into force 

 

 

2 February 2025 

 

Ban on AI systems with unacceptable risks and implementation of AI literacy requirements 

 

Unacceptable Risks 
HR needs to be satisfied their organisation is not running AI that is considered to be an “unacceptable risk” as stated in the Act (Art.5). E.gs include AI designed to infer emotion or biometric data to infer characteristics 
 
AI Literacy 
HR or L&D need to roll out basic training for all staff using frontier models such as Copilot, ChatGPT Synthesia, etc. Employees using specialised AI for tasks such as recruitment, for example, should receive additional training. 

 

2 May 2025 

 

Codes of practice from the EU Commission are expected by this date 

 

Guidance 
Watch out for these codes they should contain helpful information giving an indication of the scope of important Articles 

 

2 August 2025 

 

Entry into force of governance rules, obligations for GPAI providers, regulations on notifications to authorities, and fines. This provision applies mainly to Providers of AI 

 

AI Audit 
Around this time HR should conduct or take part in an AI audit which, among other things, assesses and records the level of risk represented by each use of AI in the organisation. This exercise will help prepare for the next key date which concerns obligations for those operating high-risk systems and also rules on AI transparency. 

 

2 August 2026 

 

End of 24-month transition period obligations for high-risk AI systems come into effect and rules on AI transparency. 

 

High-Risk AI will be AI systems for: 

  • recruitment or selection 

  • making decisions on employment conditions, promotions or terminations 

  • monitoring and evaluating performance and behaviour. 

 

  • Deployers will have to (Art.26): 

  • Ensure proper use 

  • Do data management 

  • Monitor operation 

  • Ensure record keeping 

  • Inform Affected Parties 

  • Ensure Compliance with Data Protection 

  • Conduct Annual Reporting 

Transparency  
The transparency requirements apply irrespective of whether the AI is considered to be high risk or not. 

Duty to inform user when: 

  • interacting with AI so for e.g HR chatbot (Art.50(1); 

  • using synthetic data, for example, an AI generated image (Art.50(2); 

  • using emotion recognition or biometric categorisation systems (Art 50(3); 

  • using “Deep Fakes” (for example Synthesia) where the avatar resembles a living human such as an employee (Art.50(4)) 

 

2 August 2027 

 

Obligations for high-risk AI systems as safety components come into effect; entire EU AI Act becomes fully applicable 

 

 

 
This table was drafted by Barry Philips, Chairman, Legal Island with the assistance of AI search engine Perpleixy on 10 February 2025.

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Disclaimer The information in this article is provided as part of Legal Island's Employment Law Hub. We regret we are not able to respond to requests for specific legal or HR queries and recommend that professional advice is obtained before relying on information supplied anywhere within this article. This article is correct at 10/02/2025
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