On May 7 2026, the EU decided to simplify and streamline the implementation of the EU AI Act.  

This included delaying the timeline for applying the Act’s provisions on high-risk AI systems, which includes HR uses of AI, by up to 16 months. This would mean the compliance deadline for high-risk AI would move from August 2026 to December 2027.  

This move still needs formal approval from the European Council and European Parliament, but that process is expected to be completed in the coming weeks.  

Ever since the EU AI Act was officially adopted into law in 2024, organizations, and specifically HR teams, have worked to prepare for the August 2026 high-risk deadline.  

This work isn’t just going on in Europe; the legislation has extraterritorial reach, so if your AI products or policies impact anyone inside the EU, no matter where your company is headquartered, you must comply with the Act.  

Does the change in deadline affect HR’s decision-making around AI and governance? UNLEASH put this question to HR and legal experts; here’s their advice for how HR leaders can use the deadline delay to get ahead.  

The EU AI Act delay is a ‘gift’ to HR: How to best use the additional time

For Adam Smith, Data Lawyer and Founder of Bonobo Legal, the extensions to the high-risk AI implementation deadline are “good news for the HR sector.”  

“The AI Act represents the beginning of a regulatory regime, and there needs to be some recognition that getting implementation right matters more than getting it done quickly,” he explains. 

“This, of course, further underlines the need for HR professionals to continue their compliance efforts with the same urgency as before.”  

Tami Nutt, VP of Research at Jumpstart HR agrees; she describes the EU AI Act delay as “a gift with an expiration date.” 

HR leaders who treat it as breathing room rather than a runway will find themselves in the same position when the new deadline arrives.”  

This delay is not an excuse to pause, or slow AI oversight efforts – that would be a mistake for HR teams.  

The extra time provides HR with “additional preparation time to strengthen governance practices,” notes Mosella Henry, Senior Director Analyst in Gartner’s HR practice.  

But where precisely should HR teams prioritize? What actions and decisions must they take now to ensure they use the extra time wisely?  

There are three main areas that HR must focus on, and urgently.  

ABBYY’s AI Ethics Evangelist, Andrew Pery, notes that the delay gives space to “conduct a proactive assessment of their current AI governance and risk management readiness.” 

This includes completing an AI inventory, and building an operational infrastructure, according to Jumpstart HR’s Nutt.  

Chandler Morse, Workday’s Chief Corporate Affairs Officer, and Syndio CEO Maria Colacurcio agree that visibility must be the first step.  

Documentation must be in order; “The EU AI Act requires detailed records on how models are built, tested, and improved, including how bias is identified and mitigated. You need to be able to show your work – the evidence has to hold up to regulators, employees, and legal teams,” notes Colacurcio.  

The second priority is data readiness; as Cliff Jurkiewicz, VP of Global Strategy at Phenom, put it: “If you do not understand your data, you cannot comply. Period.”  

HR should use this time to “implement more rigorous data governance best practices,” states Pery.  

The third priority must be AI literacy. Gartner’s Henry shares that organizations need to “better understand not only how these AI tools work, but also their limitations, risks and potential impact on fairness and employee trust.”  

Morse from Workday notes: “Employees should understand when and where AI is being used, and what it does and does not do, and how to raise concerns.”  

HR is not alone in EU AI Act compliance

As HR works through the above actions, it must remember that it “cannot carry this alone,” according to Legal AI Risk Manager at Lexara Advisory LLC, Constantin Razvan Gospodin.  

“AI compliance is an inherently cross-functional responsibility,” agrees Pery.  

EU AI Act compliance only works when HR, Legal, Compliance, Procurement, Security and IT are aligned around the same governance structure,” comments Gospodin.  

Gospodin adds that the organizations that will struggle with compliance are those where each function assumes that someone else was handling it.   

“Convene that cross-functional team now, with clear ownership of each obligation, before the deadline forces [you] to do it under pressure,” he continues.   

Ultimately, Jurkiewicz concludes: “The companies that use this time to get their data, their literacy and their internal alignment right will not just meet the regulation, they will outperform because of it.”  

There’s also a need for HR to look externally, and collaborate more closely with their vendors and partners.  

Jurkiewicz calls for HR teams to get more aggressive in how they evaluate tech partners; “you should be demanding to know how these systems are built, how they are tested, and how they can be explained.”  

Morse adds that HR vendors should be open about “design, data and risk controls” – “that transparency gives organizations the confidence that their AI is both compliant and trustworthy when speaking to regulators, customers or employees.”  

Gospodin reminds HR leaders that they have the leverage with vendors; “too many of them still cannot explain their training data, bias controls or how a human can meaningful challenge an outcome.”  

Do not wait until the new deadline in December 2027, before talking, scrutinizing and collaborating with vendors on AI compliance.