EU AI Act: how Formatix is classified

Summary

What Formatix does

Formatix reads documents a recruitment firm already holds (a candidate's CV, interview notes, a job description) and produces the documents the firm sends its clients: candidate profiles, blind CVs, shortlist decks, trackers, assessment reports and similar, in the firm's own Word, PowerPoint or Excel template.

• The facts come from the documents the consultant provides. Formatix is instructed to use only what they contain and not to add facts or opinions of its own.
• Ratings, assessments and the consultant's view in a document come from the consultant's notes, never from Formatix.
• Every output is an editable file. The consultant reviews it, changes it if needed and decides whether to send it.
• Formatix does not decide who is shortlisted, interviewed, offered or rejected.

Why CV formatting is not high-risk

Annex III, point 4 of the Act lists as high-risk AI systems intended for recruitment or selection, in particular to place targeted job advertisements, to analyse and filter job applications and to evaluate candidates. Formatix's CV formatting and document production do none of these:

• No filtering or evaluation. Formatting a CV changes its layout, not who is considered. Every CV uploaded comes back formatted; none is screened out, ranked or scored.
• A narrow procedural task. Moving a CV's content into a firm's template is the kind of narrow procedural task Article 6(3) describes, done on a document a person has already chosen to send.
• No profiling. Formatix does not build profiles to predict a candidate's performance, behaviour or suitability.
• Human control. The consultant chooses the candidate, the template and the content, and approves the document before it reaches a client.

Because Formatix is an AI system that produces text, the transparency duties of Article 50 are the relevant ones for these features, and we meet them as described below.

The Mandates longlist check

Mandates is a separate, optional part of the platform for running a search. When a firm uses it, Formatix checks each longlist profile against the requirements in the brief and shows the lines from the profile behind each tick, so the consultant can see why someone appears on the list. The consultant reviews every profile and makes every decision.

Because comparing candidates against requirements is close to what Annex III, point 4 describes, we are assessing this feature on its own, ahead of the date the high-risk rules for recruitment apply (2 December 2027). We will publish the outcome on this page and make any changes it calls for before that date. CV formatting and document production do not depend on it, and firms that do not use Mandates do not use this feature.

Transparency and safeguards

• Disclosure. Our website, Privacy Policy and Data Processing Agreement state that Formatix uses AI models and name the providers: Anthropic (Claude), Google (Gemini) and, as a back-up, OpenAI, with Microsoft Azure for text recognition.
• No training on customer data. We do not use uploaded documents to train AI models, and we use our AI providers under terms or settings under which they do not train on them either.
• Instructions to the models. The models are instructed to use only the source documents, not to invent facts and not to add their own opinions about candidates.
• Review before use. Outputs are drafts in editable formats; nothing is sent to a client or a candidate by Formatix without the firm's action.
• Data protection. Processing is under the UK GDPR and the EU GDPR as set out in the Data Processing Agreement, with the platform hosted in London and the sub-processors and their locations listed in its Annex 3.
• Retention. Firms can set records to delete automatically after a period they choose.

Dates that apply

Check the current text of the Regulation for your own obligations; dates and guidance can change.

Documentation and contact

We keep an internal record of this assessment: the system's functions, the models used, the safeguards and the review of the Mandates longlist check. Customers and prospective customers can ask for it, and for our Data Processing Agreement, at [email protected].

Questions about the EU AI Act and Formatix