AI Transparency Notice

An AI transparency notice is a general disclosure, usually posted publicly or shared organization-wide, stating that a company uses AI somewhere in its HR or hiring processes. It's broader than a candidate-specific notice — it establishes upfront, for anyone interacting with the company, that automation plays a role.

Regulators increasingly treat this kind of disclosure as a baseline expectation, separate from any consent obtained from a specific individual, and separate from whatever a specific candidate is told about their own application.

What Belongs in an AI Transparency Notice?

A useful notice names the general categories of AI use — resume screening, chatbot scheduling, performance analytics — without necessarily detailing proprietary model mechanics.

• Plain-language description of where AI is used in the employee or candidate lifecycle
• A contact point for questions or accommodation requests
• A general statement on human oversight of AI-assisted decisions
• A link to the more detailed candidate-specific notice where one applies

Where Does This Requirement Come From?

The EU AI Act builds transparency obligations directly into its treatment of high-risk employment systems, requiring documentation and disclosure before deployment.

In the U.S., NYC Local Law 144 achieves a similar effect at the candidate level, while broader transparency norms are increasingly shaped by industry guidance from groups like SHRM rather than a single federal statute covering every employer at once.

How Is This Different From Candidate AI Notice and Consent?

A transparency notice is the umbrella disclosure that AI is used somewhere in the process. Candidate AI notice and consent is the specific, individualized version delivered to a person before a tool evaluates their own application.

How Should HR Roll Out a Transparency Notice?

Start with an inventory of every place AI touches the employee or candidate lifecycle, since a notice can't honestly cover tools nobody remembered to list. From there, draft language that a non-technical reader can understand in under a minute.

Review the notice whenever a new AI tool is introduced, and treat it as a living document rather than something written once during a compliance sprint and never revisited.

Who Should Own the AI Transparency Notice Internally?

HR is usually the right owner since it sees every AI touchpoint across the employee and candidate lifecycle, but legal should review the final language before it's published anywhere external.

Assigning a single owner, rather than leaving it as a shared responsibility, is what usually keeps the notice current when a new tool gets adopted mid-year instead of at the next scheduled policy review.

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Frequently Asked Questions

Q: Is an AI transparency notice legally required?

A: It's increasingly expected under frameworks like the EU AI Act, and functions as good practice even where not strictly mandated.

Q: Does it need to explain how the AI model works technically?

A: No. It should describe where and why AI is used in plain language, not disclose proprietary technical details.

Q: Who should publish the notice?

A: Typically HR and legal jointly, often published on the careers page or in an employee handbook.

Q: How is it different from a privacy policy?

A: A privacy policy covers data handling broadly; an AI transparency notice specifically addresses automated decision-making.

Q: Does one notice cover every AI tool a company uses?

A: It can serve as an umbrella statement, but high-risk tools may still need their own specific candidate notice.

Q: How often should it be updated?

A: Whenever a new AI tool is introduced into the hiring or employment process, or an existing one changes significantly.