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  <front>
    <journal-meta>
      <journal-title-group>
        <journal-title>Oficial Journal of the European Union</journal-title>
      </journal-title-group>
    </journal-meta>
    <article-meta>
      <article-id pub-id-type="doi">10.1145/3236009</article-id>
      <title-group>
        <article-title>A Survey on Human Resource Management Under the AI Act: Ethical, Practical, and Regulatory Perspectives</article-title>
      </title-group>
      <contrib-group>
        <contrib contrib-type="author">
          <string-name>Nicola Alboré</string-name>
          <xref ref-type="aff" rid="aff0">0</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Alessandro Castelnovo</string-name>
          <xref ref-type="aff" rid="aff0">0</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Matteo Della Valle</string-name>
          <xref ref-type="aff" rid="aff1">1</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Andrea Ermellino</string-name>
          <xref ref-type="aff" rid="aff0">0</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Luca Puggini</string-name>
          <xref ref-type="aff" rid="aff0">0</xref>
        </contrib>
        <contrib contrib-type="author">
          <string-name>Silvia Tessaro</string-name>
          <xref ref-type="aff" rid="aff0">0</xref>
        </contrib>
        <aff id="aff0">
          <label>0</label>
          <institution>Data &amp; Artificial Intelligence Ofice, Intesa Sanpaolo S.p.A.</institution>
          ,
          <country country="IT">Italy</country>
        </aff>
        <aff id="aff1">
          <label>1</label>
          <institution>Università Milano Bicocca</institution>
          ,
          <addr-line>Milano</addr-line>
          ,
          <country country="IT">Italy</country>
        </aff>
      </contrib-group>
      <pub-date>
        <year>2023</year>
      </pub-date>
      <volume>2</volume>
      <fpage>52138</fpage>
      <lpage>52160</lpage>
      <abstract>
        <p>This paper explores the integration of artificial intelligence into human resource management, focusing on its ethical, practical, and regulatory implications. As digital transformation reshapes human resources practices, artificial intelligence ofers potential for increased eficiency and innovation, but also raises challenges related to fairness, transparency, and governance. Key areas such as fairness in decision-making, system explainability, and human oversight are examined to assess their impact on recruitment processes, employee well-being, and organizational performance. By critically analyzing these aspects, the study highlights the dual role of artificial intelligence in improving inclusion while exposing the risks of perpetuating bias and reducing accountability. Building on existing literature, this review discusses how organizations can balance technological advancements with ethical principles to promote trust and equity in the workplace. In addition, it calls for strengthened regulatory frameworks and collaborative eforts between policymakers, practitioners, and technologists to ensure responsible artificial intelligence deployment. By addressing these issues, the study aims to contribute to the development of sustainable human resource practices that align technological progress with organizational and social values.</p>
      </abstract>
    </article-meta>
  </front>
  <body>
    <sec id="sec-1">
      <title>1. Introduction</title>
      <p>
        As organizations deal with increasingly complex workforce and societal dynamics, implementing
wellsuited human resource management (HRM) policies has become a key priority. The strategic resonance
HRM practices yield within organizations, which impacts firm performance and employee satisfaction,
has pivoted significant attention within both academic and industrial environments [
        <xref ref-type="bibr" rid="ref1 ref2 ref3 ref4">1, 2, 3, 4</xref>
        ].
      </p>
      <p>
        Despite some criticism about the potential detrimental efects of HRM practices geared towards
companies on employee wellbeing [
        <xref ref-type="bibr" rid="ref2 ref3">2, 3</xref>
        ], many consider HRM an instrumental approach that allows
organizations to perform better [
        <xref ref-type="bibr" rid="ref5 ref6 ref7 ref8 ref9">5, 6, 7, 8, 9</xref>
        ]. Not only by pursuing a positive renewal of work
environments, but also by allowing better engagement by employees, thus orienting HRM towards
"common good" values, centered around the need for sustainability and progress [
        <xref ref-type="bibr" rid="ref10 ref11">10, 11</xref>
        ]. Some scholars
suggested that both employers’ productivity and employee wellbeing should not be viewed as competing
objectives, but rather as complementary goals that could be reached together [
        <xref ref-type="bibr" rid="ref12">12</xref>
        ]. However, it is still
not clear how this joint optimization could be carried out [
        <xref ref-type="bibr" rid="ref13">13</xref>
        ], and the ethical aspects surrounding the
dificult balance between the prioritization of employees’ needs and company goals [
        <xref ref-type="bibr" rid="ref14 ref15">14, 15</xref>
        ].
      </p>
      <p>
        In today’s economic landscape defined by a strong need for digitalization and a concurrent race for
information harvesting [
        <xref ref-type="bibr" rid="ref16 ref17">16, 17</xref>
        ], data has become a critical catalyst for innovation [
        <xref ref-type="bibr" rid="ref18">18</xref>
        ]. At the forefront
of this digitalization [
        <xref ref-type="bibr" rid="ref19">19</xref>
        ], the development of machine-based systems designed to operate with varying
levels of autonomy, potentially exhibiting adaptiveness after deployment, and generating outputs—such
as predictions, recommendations, or decisions—that influence physical or virtual environments, has
found its perfect application [20]. However, the need to harness, process, and interpret data poses
new challenges in understanding how companies should not only pursue firm return optimization, but
also address human capital, especially for strategic decision-making [
        <xref ref-type="bibr" rid="ref19">19, 21</xref>
        ]. A larger commitment to
technological funding is more feasible for tech-focused industries due to their substantial resources
[22, 23].
      </p>
      <p>Despite some mild skepticism [24, 25] regarding the negative efects that impact the management
of human resources from such technologies, many have noted that a greater efort towards AI-based
solutions boosts organizational growth [26], competitive advantage, and also reduces operational costs,
thus leveraging a more attractive work environment [27, 28].</p>
      <p>The need to align current HRM standards with recent advances in the field of AI development or
computer science is generally justified by the impact on attracting and retaining motivated
employees, due to the integration of a personalized, eficient and supportive workforce within organizations
[29, 30]. In particular, many organizations have integrated AI-driven tools into their HRM systems to
enhance various processes. In recruitment and onboarding, AI aids in pre-screening candidates,
accelerating interviews, and identifying the best-fit applicants [ 31, 32]. For development and performance
management, it helps track and predict learning needs, assess employee performance, and support
managers in identifying strengths and areas for improvement [33, 34]. Additionally, in engagement and
retention, AI analyzes employee sentiment, predicts turnover, and recommends resources to promote
mental and physical well-being [35, 36]. Although these contributions are promising, the ethical
implications of AI in HRM remain controversial [37]. The unprecedented insight and eficiency ofered
by AI is accompanied by the complexity of its underlying algorithms and methods, leading many to
question whether such tools inadvertently reinforce biases, compromise privacy, or lack suitability for
autonomous decision-making [38, 39, 40, 41]. This has sparked calls for deeper studies, particularly in
HRM, given its significant influence on individual and organizational innovation [21, 42, 43].</p>
      <p>
        The importance of addressing these concerns is underscored by the proactive eforts of the European
Union to regulate AI [
        <xref ref-type="bibr" rid="ref12">12</xref>
        ]. In April 2021, the European Commission introduced the first proposal
for a “Regulation laying down harmonized rules on artificial intelligence” (AI Act) [ 44], which, in
its definitive version, oficially came into force on 1 August 2024. An important focus of the AI Act
is on high-risk AI systems, including those used in hiring processes and people management, both
of which are pivotal to the HRM sector. It emphasizes the protection of fundamental human rights,
from which ethical principles like fairness, transparency, explainability, and human oversight naturally
emerge as essential requirements for AI systems developed in this context. Rather than restricting AI
adoption, the Act provides a framework of essential guidelines to promote the ethical and responsible
use of AI-driven solutions. By rooting these measures in the values and fundamental rights of the EU,
the AI Act seeks to build trust in AI technologies while encouraging innovation and progress within
organizations [45]. This paper responds to this request by conducting a literature review, ofering an
initial overview of ethical issues in the use of AI and its reflection on HR practices. After identifying key
ethical opportunities and risks, we discuss and propose recommended practices to efectively manage
these risks. Considering the profound impact recruitment decisions have on the lives of individuals
[46], companies need to recognize both the benefits and the potential drawbacks of AI and understand
how algorithmic decisions can sometimes conflict with their intended outcomes [47].
      </p>
      <p>This paper contributes by providing a comprehensive literature review based on the key ethical
pillars outlined in the AI Act—fairness, explainability, and human oversight—applied specifically to
the HR sector. We evaluate 31 articles from top-tier journals, scoring and ranking them based on the
level of detail provided. Additionally, we classify each article’s perspective on AI adoption, categorizing
it as presenting AI as an opportunity, a threat, or both. This analysis ofers valuable insights into the
ethical implications of AI in HR, helping organizations navigate the complexities of responsible AI
implementation in recruitment and people management.</p>
      <sec id="sec-1-1">
        <title>1.1. Key Ethical Pillars and Requirements in the AI Act</title>
        <p>The Act aims to foster responsible artificial intelligence development and deployment in the EU, limiting
risks of unintended societal impacts, such as reinforcing biases, compromising privacy, and making
opaque or unaccountable decisions that afect individuals’ lives and rights [ 48, 49]. The AI Act is a
pioneering legislative framework designed to establish comprehensive standards for the ethical, safe,
and human-centered use of AI across Member States. The regulation aims not only to protect citizens
from potential risks but also to set a global standard, positioning Europe as a leader in responsible AI
governance. The Act draws heavily on the EU’s 2020 White Paper on Artificial Intelligence [ 50], which
outlined the importance of upholding values such as human dignity, inclusion, and non-discrimination
in AI applications. By instituting this framework, the EU underscores the importance of aligning AI
innovation with fundamental rights, aiming to prevent a fragmented regulatory landscape within
Europe and to establish a benchmark for AI standards worldwide. Building on a risk-based approach,
the European Union has chosen to implement stringent regulations for high-risk systems, including, as
previously mentioned, systems used for personnel evaluation and selection. Requirements for high-risk
AI systems underline their essential role in safeguarding fundamental rights and fostering public trust.
Three key ethical pillars to consider for mitigating the risks of introducing AI in delicate and highly
sensitive sectors, such as HRM, are fairness, explainability, and human oversight.</p>
        <p>1. Fairness: this pillar is prioritized to address the potential for AI systems to reinforce or even
amplify existing societal biases and to ensure equality, promoting equitable outcomes for all
individuals, regardless of demographic background. In applications like recruitment, credit
scoring, or law enforcement, biased algorithms can lead to unjust outcomes, disproportionately
afecting certain demographic groups. The AI Act mandates robust bias mitigation techniques,
requiring developers and providers to implement mechanisms that continually monitor and
reduce discriminatory efects throughout the AI lifecycle. This ensures that fairness is not just a
design goal but an ongoing responsibility as systems evolve and adapt.
2. Explainability: another crucial factor, especially in complex AI applications where decisions
afect individual rights or societal welfare. High-risk AI systems are required to provide suficient
transparency, enabling users and possibly afected individuals to understand how and why
decisions are made. This is particularly significant in sectors such as employment and justice,
where AI-driven decisions can have life-altering consequences. The Act’s focus on explainability
demands that AI systems are developed and used in a way that allows appropriate tracebility
and transparency, making possible for users to grasp the systems’ capabilities and, if necessary,
challenge their outputs, in order to guarantee human autonomy and dignity.
3. Human Oversight: This pillar ensures control over AI systems and fixing accountability for
the use of such systems. While AI is designed to operate independently, the Act stresses the
importance of having human supervisors who can intervene if necessary. In high-risk areas,
human oversight serves as a safeguard against potential errors or unforeseen consequences in AI
behavior. By maintaining a human element in decision-making processes, the Act promotes a
balanced approach that respects both technological autonomy and human judgment, particularly
in critical sectors where the stakes are high.</p>
        <p>These three ethical principles: fairness, explainability, and human oversight are essential to the
ethical framework of the AI Act. They establish that high-risk AI systems must operate within clearly
defined ethical and legal boundaries, ensuring that AI not only advances technological frontiers but does
so responsibly, with a strong commitment to societal values. This approach highlights the commitment
of the EU to maintaining ethical integrity in AI usage, emphasizing that regulatory measures are
indispensable in high-stakes applications to protect public trust and individual rights. These three
pillars form the foundation of the literature review presented in this paper.</p>
      </sec>
    </sec>
    <sec id="sec-2">
      <title>2. Review</title>
      <sec id="sec-2-1">
        <title>2.1. Research Methodology</title>
        <p>To understand the perspective of the international scientific community on the aforementioned topics,
articles published in relevant and high-impact scientific journals and articles were selected. These
sources were chosen based on their relevance, impact on citations, and recognized authority in the
ifelds of AI and HR. The selection process involved the identification of leading journals in the domains
of artificial intelligence, computer science, and HR management. Extensive searches were conducted in
various academic databases using keywords related to fairness, explainability, and human oversight in
AI. The inclusion criteria involved the date of publication of the article to ensure the inclusion of recent
and relevant studies, the number of citations as an indicator of influence, and the impact factor of the
journal to ensure high-quality and credible sources. By focusing on these parameters, the research
aimed to incorporate a diverse and comprehensive collection of scholarly works that reflect the current
state of academic discourse on these critical issues. The selected articles were evaluated and classified
according to their discussion of the three key topics according to the following criteria:
• Score 1: The article discusses the topic in general terms, without delving into specifics, and does
not provide a detailed theoretical definition nor refer to hypothetical or real cases.
• Score 2: The article provides a theoretical definition of the topic, but does not present examples
of hypothetical or concrete applications.
• Score 3: The article explores the topic through a hypothetical case or by theorizing a personal
algorithm.
• Score 4: The article presents a real case of business or workplace application of the discussed
topic, or a survey of the population to gather opinions on the subject.</p>
        <p>After giving a score, we further classified the articles for each topic as follows:
• Opportunities (O): Articles in which the authors are in favor of introducing AI into the field of
human resources, as they believe that it could promote greater equity compared to traditional HR
ofice practices.
• Threats (T): Articles in which the authors are not entirely opposed to the introduction of AI in
the field of human resources but still believe that it would not be the solution to ensure greater
equity; on the contrary, these authors highlight the threats arising from its use, which due to its
functioning could end up exacerbating and automating biases and unfair decisions.
• Both (O/T): Articles in which the authors highlight both the significant opportunities and risks
associated with the use of AI.</p>
      </sec>
      <sec id="sec-2-2">
        <title>2.2. Fairness</title>
        <p>A substantial portion of the reviewed literature supports the integration of AI systems into routine HR
practices, particularly in recruitment and selection processes. Currently, it has gained some traction, as
companies have started to implement AI-based software [77], to leverage AI to correlate social media
activity with long-term retention predictors, a factor previously unconsidered in traditional methods
[69], or to obtain an efective bias reduction system, highlighting AI’s ability to promote fairer hiring
results [82].</p>
        <p>Several scholars contend that AI’s widespread adoption streamlines routine HR tasks while crucially
mitigating the biases intrinsic to human judgment [83]. Given that human subjectivity in hiring and
selection processes is inherently limited in its reliance on objective data alone, a meticulously designed
AI algorithm can potentially mitigate many sources of bias, promoting fairness in these activities. At
the same time, its unrestrained deployment could raise concerns by inadvertently reinforcing and
institutionalizing algorithmic biases, underscoring the critical need to properly assess the structural
integrity of software tools disposed of by HR operators. We note, for example, Amazon’s
algorithmbased hiring system, which operated from 2014 to 2018, but was abandoned after it was found to
discriminate against women in IT roles, having been trained on data favored male applicants. Despite
Amazon’s attempts to neutralize gender indicators, the inherent bias of the algorithm could not be
suficiently corrected, leading to its discontinuation [ 84]. Similarly, companies that use Facebook’s
targeted recruitment tools have faced criticism for excluding certain demographic groups based on
social media data and targeted lookalike audiences. This practice, which restricts job advertisements to
specific groups, is not only ethically problematic but also contravenes legal standards, including the
European AI Act and Title VII of the U.S. Civil Rights Act [59, 85]. To examine the factors through
which AI can foster but also threaten fairness in HRM, we highlight several themes.
• Inclusive Language in Job Advertisements: human-written job advertisements often
unintentionally incorporate biased language that can exclude certain demographic groups. AI-powered
software, while not entirely flawless, can flag such phrases to prevent exclusionary language
in recruitment campaigns. For such reasons when algorithms are not appropriately developed,
they may also introduce biases, underscoring the importance of continuous human oversight,
as outlined by the AI Act [50, 85]. Thus the need for AI tools to assist companies in crafting
unbiased job advertisements, fostering inclusivity by evaluating candidates based on skills rather
than personal attributes.
• Implementation of Fair CV Screening Practices: AI applications in CV screening represent some
of the earliest examples of AI’s influence in HR. AI not only accelerates these processes but
can also reduce the risk of bias. Literature suggests that without AI, human-only screening
can lead to discrimination based on gender [86], minority status [87], and age [88], potentially
restricting access for these groups in the labor market. By focusing on predefined criteria during
the design phase, AI minimizes unconscious biases, filtering candidates objectively without regard
to subjective human factors like physical appearance or first impressions, which are often dificult
to avoid or identify in traditional evaluations.
• Evaluation of Candidates’ Skills and Traits: AI-based assessment tools have introduced innovative
approaches to evaluating candidates, particularly by using simulations and gamified assessments
to capture diverse data on candidates’ competencies. Traditional methods, such as tests and
surveys, have faced criticism since the 1970s for their limitations in assessing complex human
potential [82]. Recent AI-driven assessments allow candidates to engage with designed scenarios
that mimic workplace tasks, capturing responses and strategies in real-time. Such methods
alleviate candidates’ typical interview anxiety, enabling full engagement and mitigating biases
associated with identity by focusing solely on in-game performance data.
• Interviews for Screened Profiles: AI has transformed the interview process by facilitating
structured and bias-resistant candidate evaluations. The reviewed studies critique the traditional
reliance on human intuition in interviews, noting that intuition is inherently subjective and prone
to biases, which can undermine fair hiring outcomes [69]. By automating structured interviews,
AI can assess extensive data beyond human capacity, focusing on the qualifications necessary for
reliable performance while disregarding irrelevant, bias-prone data points. However, researchers
emphasize that algorithms must be carefully designed to prevent embedding human biases into
AI-driven systems, as algorithmic output is highly dependent on initial design inputs and training
data [89].
• Mitigation of Implicit Bias: Implicit bias, defined as an unconscious negative attitude toward
certain social groups, poses a challenge in recruitment and selection, as it influences perceptions
and behaviors beyond conscious awareness. Some have noted the role of AI as an external
moderator of implicit bias, enabling organizations to identify and address such biases in real-time
[90]. AI can reveal patterns or characteristics that contribute to successful job performance while
eliminating biases related to protected characteristics. Others suggested strategies for reducing
implicit bias, which require a combination of technical and procedural improvements. Efective
reduction strategies include anonymizing demographic data and emphasizing cultural and social
commitments to inclusivity.
• Bias from Historical Data: AI models trained on historical data can perpetuate existing inequities
if the underlying data reflect past discriminatory practices. For instance, if a company has
historically favored certain demographic groups, AI models trained on such data are likely to
replicate and amplify these biases in recruitment outcomes [73, 91]. To mitigate this, developers
are urged to identify and rectify biases within training data, utilizing strategies such as removing
category-linked attributes that are irrelevant to job performance [76]. Additionally, causal
discovery techniques, which seek to link variables directly related to job performance rather
than demographic attributes, are recommended to improve fairness. Although causal discovery
remains a developing field, it holds promise for distinguishing individual-specific factors from
general category traits [92, 93]. Explicit randomization during selection, wherein candidates
with identical recommendation scores are chosen randomly, has also been suggested to prevent
entrenched discriminatory practices [76, 91].
• Bias Based on Category Membership: Discrimination based on category membership, such
as gender, ethnicity, or other demographic attributes, is a longstanding issue that algorithms
may not efectively address. For example, studies report an under-representation of women,
Latino-Americans, and African-Americans in technology roles in the United States, partly due to
high turnover among these groups resulting from workplace biases [59]. Furthermore, selection
algorithms are often designed by homogeneous teams, which may unintentionally embed biases
within the algorithm’s structure, favoring candidates from similar backgrounds [81]. Bias persists
for three primary reasons: first, recruiters determine algorithmic outputs; second, designers
embed specific performance-related factors that may inherently favor certain groups based on
company data; and third, factors such as university afiliation or demographic membership,
often linked to successful performance, can exclude diverse candidates from consideration [51].
AI systems, rather than eliminating these exclusions, may unintentionally highlight standout
members from overrepresented groups [94]. Additionally, cultural diferences in expressions and
behaviors present challenges in video-interview AI tools, as models trained on culturally specific
data may misinterpret candidates from diferent backgrounds [54].
• Proxy Discrimination: Proxy discrimination occurs when AI systems infer protected category
information through correlated non-protected attributes, resulting in indirect yet substantial bias
[180, 204]. Despite eforts to eliminate biases, implicit associations embedded in historical data
are dificult to remove, leading to covert discriminatory outcomes [ 95, 66]. Mitigation strategies
include anonymizing demographic information and utilizing neuroscience or chatbot-based data
collection methods that focus exclusively on job-related skills and characteristics. The use of
avatars to replace human interviewers is another technique proposed to reduce the impact of
proxy discrimination [62, 80]. Although these methods represent considerable eforts toward
eliminating bias, complete removal of implicit biases remains challenging, underscoring the
continued need for advancement in bias-mitigation strategies [51].
• Disparate Impact: This phenomenon describes the unintended adverse efects on protected
categories resulting from ostensibly neutral policies or algorithms. Techniques to reduce disparate
impact, such as masking sensitive attributes, are proposed in the literature, along with adjustments
to algorithmic language and labeling to ensure fairness [66]. Under United States law, managers
can defend against disparate impact claims by proving that selection criteria serve a business
necessity and that no reasonable alternative methods exist. This burden of proof then shifts to
the complainant, who must demonstrate viable alternatives [46].</p>
      </sec>
      <sec id="sec-2-3">
        <title>2.3. Explainability</title>
        <p>The second topic we focus on is explainability. By this term, we mean the ability for humans to clearly
understand how an artificially intelligent system works and is able to output decisions (Explainable AI,
n.d.). The need to understand how and why an AI system made a specific decision is crucial not only to
ensure transparency and fairness but also to adhere to the ethical and legal principles established by
current regulations.</p>
        <p>Before delving into the chapter, it is helpful to clarify the term "explainability." Although there is no
universally accepted definition of XAI (eXplainable Artificial Intelligence), terms such as "understanding,"
"interpreting," and "explaining" are often used interchangeably. Typically, interpretability refers to
understanding how a predictive model works, while explainability is related to models that are inherently
more complex and dificult to understand. From a regulatory perspective, both the GDPR and the EU
AI Act outline important provisions and stringent norms concerning explainability. These regulations
require that the providers and users of AI systems comply with specific requirements to ensure that
their tools can provide clear explanations of their operations and decisions [85, 96]. The GDPR, for
example, grants individuals the right to receive meaningful information about the logic involved in
automated decision-making and profiling [ 96]. Similarly, the AI act places a strong emphasis on
promoting transparency, accountability, and human oversight in AI systems, ensuring that they align
with European values and fundamental rights [85]. In this chapter, we will explore the main criticisms
raised by scholars on this topic, addressing the issue of "black-box" algorithms. We will then explain
how the theme of explainability relates to the two core legislative frameworks in Europe.</p>
        <sec id="sec-2-3-1">
          <title>2.3.1. The Problem of ’Black Box’ Algorithms in HR Techniques</title>
          <p>Our review of the modern literature focused on explainability has highlighted that all articles raise
the issue of ’black box’ algorithms. A ’black box’ algorithm is defined as such because users cannot
determine how the algorithm made a particular decision [97]; it is an algorithm where users can
only know the input data provided to the algorithm and receive the output data from it without fully
understanding why it is providing those data. Naturally, this inability on the users part raises significant
issues in terms of opacity, non-transparency, and lack of clarity in decision-making. In specific HRM
practices, such as selection process regulated by algorithms, it would be dificult to explain exclusion
of candidates if the technology underlying such processes are of "black box" type [71]. If recruiters
cannot provide an accurate explanation of the process through which the algorithm made that decision,
it leads to significant issues not only from an ethical and social point of view, with unpredictable and
destructive damage caused to individuals [94], but also legal problems, given the legislative boundaries
imposed by GDPR and the AI Act. We highlight from our analysis various points:
• Obligation to interpretability: users of the algorithms have an obligation to fully understand
the functioning of the software they are using, and companies themselves should draft ethical
reports informing how their HR ofice, or any department using AI systems, utilizes such tools
[51]. It is certainly not a simple operation. In fact, for "black box," we can also refer to those
algorithms that are well understood and have impressive predictive capabilities, but whose
predictive relationships are too complex to interpret [98]. Considering HR practices, even when
recruiters obtain selection data using sound practices, and those data and the algorithms used
to interpret them demonstrate stronger robustness compared to traditional methods, there still
remain gray areas of interpretability. It is not guaranteed that the detected patterns of prediction
will reflect important and interpretable constructs [55].
• Trade-of between complexity and explainability: the more complex an algorithm is, the more
accurate it will be, but the less easy it will be to understand and explain [76]. Some argue that an
automated algorithm that makes its decisions based on input provided and considers dozens of
factors simultaneously cannot be as simple to explain to another which employs just a few. This
is why most machine learning-based algorithms are capable of easily finding patterns through
associations rather than causal explanations [76]. Patterns between data, despite some shade of
reality in business contexts, they would still raise issues from an ethical and legal standpoint, as
they would favour or exclude individuals based on sensitive and protected characteristics. Causal
reasoning, on the other hand, can be a significant challenge for organisations using such tools, as
it can meet the requirements of fairness and explainability [62, 76]. Methodologically speaking,
causal discovery is a rapidly developing technique that automates the empirical verification
of causal hypotheses, narrowing down plausible causal models for consideration and
decisionmaking [92].
• Lack of employees training on AI policies: the public’s lack of access to all information regarding
the use, design, bias reduction methods, and transparency of algorithms used by companies in
selection processes is a major drawback for companies [71]. Without access to comprehensive
information about AI tools, it becomes challenging to determine if an algorithm is fair or
explainable when information is kept private. Sometimes, machine learning models may be inaccessible
to the public due to legal reasons or at the companies’ discretion to protect user data privacy in
their selection processes, but valuable insights can still be gleaned from what companies have
made publicly available. This includes insights into bias reduction and transparency [71]. Such
analysis also sheds light on the issue of explainability. Specifically, machine learning techniques
excel in identifying correlations between certain factors and outcomes, predicting how a subject
might behave, which can be beneficial or detrimental to what the company seeks. However, the
challenge arises when experts cannot explain why the presence or absence of a specific factor may
impact future performance. For instance, why a candidate’s tone of voice might afect their job
performance [71]. This circles back to the previously discussed problem where the more precise
an algorithm becomes, the less understandable its correlations are to users and experts alike due
to the increasing number of variables considered [76]. Moreover, if experts cannot explain these
correlations and outputs provided by the algorithm, it raises concerns that the algorithm may
unknowingly use sensitive factors or data for its analysis, potentially compromising the fairness
of the selection process. International public opinion has voiced numerous criticisms regarding
the use of facial, vocal, and emotional analyses [99, 60] This makes it impossible for a human
recruiter to determine if the AI-driven algorithm inadvertently learned sensitive characteristics,
thereby compromising the fairness of its usage.
• Privacy concerns around employees data: employers today already possess a lot of user data,
including mailing addresses, bank account details for salaries, CVs for the hiring process, and
even medical details for requesting sick leave. Having all this data available allows employers to
perform HR analytics without directly involving employees; for example, a group of employees
might be considered at low risk of leaving the company, and consequently, policies for this
group would be influenced by these analyses, such as smaller salary increases or less expensive
training [100]. These operations should be condemned both ethically and legally as they obscure
transparency in the employment relationship. Those who use AI systems to make predictions
must always communicate which data they use, the purpose of such operations, and how the
algorithm makes decisions, providing a comprehensible explanation for users. This principle
allows employees to be protagonists in their own careers rather than passive subjects to company
policies [100].</p>
        </sec>
      </sec>
      <sec id="sec-2-4">
        <title>2.4. Human Oversight</title>
        <p>This chapter of the review analyzes in detail the role of human control over AI technologies in HRM,
especially its risks and positive outcomes. We focused on the reasons behind such intervention and we
also explored the European AI Act as an innovative approach to strengthening this control.</p>
        <sec id="sec-2-4-1">
          <title>2.4.1. The importance of human in the loop</title>
          <p>Public fear often centers on AI-driven job displacement. However, AI in HR aims to foster
humanmachine collaboration [57, 83], not replacement. This collaboration improves HR processes such as
recruitment, learning, and development by performing both "augmentation" and "automating" tasks [57].
More specifically, augmentation refers to human-machine collaboration in strategic decisions, while
automation denotes full machine replacement of routine tasks [57]. Although this could theoretically
displace some workers, it can also create new opportunities [101]. By easing the role of recruiters [78],
AI allows them to focus on higher-value activities, proving how essential data-driven recruitment has
become. Despite promising eforts, algorithms are not inherently neutral and can sometimes reflect the
biases of their human creators, which justifies why automated decision-making in recruitment should
be avoided; human review, especially by bias-trained experts, is crucial [51, 69]. Although complete
algorithmic neutrality is impossible, developers and recruiters must actively work to identify and mitigate
biases through software testing [51]. Simply removing sensitive input data is insuficient due to proxy
variables [102]. More complex debiasing methods compromise predictive efectiveness. Algorithmic
software should support, not replace human recruiters, making human oversight crucial to protecting
organizations and employees’ rights [51, 78, 103]. We note the case of a multinational company’s
AI-based trainee selection application, which, despite being designed for fairness, incorporated human
oversight at every stage. This prevented fully automated decisions and allowed for corrections [104].
Human intervention proved paramount, as the HR department identified repeated violations, such
as the creation of multiple accounts to manipulate scores [78]. Various techniques to reduce implicit
bias in recruitment have been presented [62]. Creating control and experimental groups with identical
qualifications but diferent demographics allows biometric data collection, revealing recruiter biases
through body language, speech, and stress levels [105, 106]. Technologies such as natural language
processing can predict and mitigate biased decisions in real time [62], but are far from being reliably
employed. A possibility would be to combine diverse human recruiters with AI agents through various
algorithms [62] or even by providing concise explanations in ranking systems [103], showing why
one item is ranked higher than another [107]. Although this helps decision-making, it is the fact that
ifnal decisions remain with human experts who consider context and nuances not captured by the
algorithm that ensures ethical alignment [103]. As many have pointed out, despite some privacy and
confidentiality concerns [ 62, 69], the importance of extensive data collection and analysis, not just for
candidate evaluation [76], becomes evident for nuanced decision-making, to ensure diversity in hiring
outcomes [79], as oversight processes that identify strong correlations between decisions and sensitive
attributes (e.g., race) help mitigate bias before algorithm implementation [79].</p>
        </sec>
      </sec>
    </sec>
    <sec id="sec-3">
      <title>3. Discussion</title>
      <p>The intersection of AI and HRM is not only a technological advancement, but also an ethical and
organizational challenge. The three pillars of fairness, explainability, and human oversight provide the
framework to evaluate AI integration into HR processes. Although these pillars represent important
ethical commitments, their enforcement raises critical questions about AI feasibility, implementation,
and broader implications for both employees and employers. We argue that by critically analyzing these
elements, both the strengths and blind spots in the literature and the practices surrounding AI-driven
HRM can be revealed. From the reviewed studies, 42% primarily view AI in HRM as an opportunity,
while 55% adopt a dual perspective, acknowledging both its potential and associated risks. A small
minority of 3% focus exclusively on the threats AI poses to HR processes (Tab. 1).</p>
      <p>Fairness is often heralded as a solution to systemic human biases in hiring, promotions, and
performance assessments. The literature emphasizes the ability of AI to lfiter candidates objectively and
minimize discriminatory tendencies inherent in human judgment [77, 62]. However, this optimism may
be overstated. Bias in AI is not an exception, but an outcome of the systems it reflects. In particular,
more than half of the reviewed studies emphasize the dual nature of AI in fairness, recognizing its
ability to address systemic bias while simultaneously perpetuating inequities through historical data
dependencies (Tab. 1). The reliance on historical data, which can encode past inequities, challenges
the premise that AI is inherently more equitable than human decision-makers. For example, while
the review acknowledges the value of inclusive language and CV screening algorithms [69, 76], it
fails to adequately address how these tools may perpetuate structural biases in less visible forms,
such as proxy discrimination [46]. Even seemingly objective criteria, such as education or experience,
may inadvertently disadvantage underrepresented groups if these attributes correlate with historical
inequities [66]. Moreover, the emphasis on fairness presumes that it is a static property to be designed
into AI systems. In reality, fairness is a dynamic and context-dependent value. Organizations may
prioritize fairness diferently depending on their objectives, such as diversity, meritocracy, or eficiency
[59, 73]. However, AI systems lack the adaptive capabilities to reconcile these competing values without
human intervention. For employees, this rigidity risks reducing complex identities to predefined metrics,
while for employers, it limits the adaptability of HR strategies to address unique workforce challenges.
Fairness, then, is not a guaranteed AI output, but a contested and negotiated process requiring sustained
human oversight [82].</p>
      <p>The second pillar of ethical AI usage, explainability, is positioned as a mechanism for transparency
and trust in AI systems. The review rightly critiques the "black box" algorithms for their opacity,
but its proposed solutions, such as ethical reporting and causal discovery techniques, fail to address
the systemic barriers to explainability [97, 46]. The trade-of between algorithmic complexity and
interpretability is more than a technical challenge; it reflects a broader tension between eficiency and
accountability. Advanced machine learning models often produce outputs that are dificult to rationalize,
not because of a lack of efort, but because their inner workings are designed to optimize predictive
power, not clarity [98, 76]. This raises critical ethical concerns. Can HR decisions be considered fair or
justifiable if their underlying processes are incomprehensible, even to experts? [ 100, 55]. Moreover,
explainability eforts often focus on post hoc rationalizations rather than proactive transparency. This
reactive approach risks reducing the explainability to a formality, satisfying regulatory requirements
without truly addressing the ethical implications of opaque AI systems. For employees, this creates a
disempowering environment in which decisions about their careers are made by systems they cannot
question. For employers, it undermines the legitimacy of AI-driven decisions, exposing organizations
to reputational and legal risks. The explainability must then be reimagined not as a technical feature
but as an integral part of AI development, requiring a cultural change in how organizations design,
deploy, and evaluate AI systems [72, 103].</p>
      <p>
        Lastly, human oversight, presented as a safeguard against the excesses of autonomous AI systems,
is itself a contested concept. The review lauds human intervention as a necessary counterbalance to
algorithmic biases, but this perspective risks oversimplifying the complexities of human-AI interaction
[78, 51]. Human oversight is not a panacea; it introduces its own challenges, including the potential
for bias, fatigue, and overreliance on AI recommendations. For example, the concept of "automation
bias" suggests that human reviewers can respect the output of AI even when it is flawed, afecting
the very purpose of the oversight [57, 62]. Furthermore, the review’s focus on technical oversight
mechanisms, such as bias detection and audit processes, neglects the organizational and cultural
dimensions of efective human-AI collaboration. Oversight is not merely about identifying errors,
but about embedding ethical deliberation into decision-making processes. The prevalence of
dualoriented studies also reflects the critical role of human oversight in balancing AI eficiency with ethical
considerations (Tab. 1. This requires training HR professionals not only in technical competencies but
also in ethical reasoning and critical thinking. The absence of such training risks reducing oversight
to a superficial practice, where human involvement is nominal rather than substantive [ 79, 76]. For
employees, inefective oversight erodes trust in the system, while for employers, it compromises the
ethical and operational integrity of HRM practices. In addition, investing in comprehensive training
and development programs, pursuing a stronger technological orientation [
        <xref ref-type="bibr" rid="ref13">13, 108, 109</xref>
        ] could reduce
workforce stress [110]. More broadly, the emphasis on human oversight raises fundamental questions
about the division of labor between humans and machines in HRM. Although the review highlights
the potential for AI to augment rather than replace human decision making, it underestimates the
organizational restructuring required to achieve this balance. Human oversight is not simply an
addon to existing HR processes; it requires a rethinking of roles, responsibilities, and workflows. For
employees, this could mean greater participation in decision-making processes, fostering a sense of
agency and inclusion. For employers, it ofers an opportunity to align AI-driven processes with broader
organizational values, but only if oversight is integrated thoughtfully and strategically [103, 100].
      </p>
    </sec>
    <sec id="sec-4">
      <title>4. Conclusions</title>
      <p>This paper contributes to the literature by providing a comprehensive review of articles discussing the
implementation of AI-based decision systems in the HRM sector. Specifically, we structure our review
around the three main ethical pillars of fairness, explainability, and human oversight, ensuring a focus
on the ethical considerations that arise when AI is applied to high-risk contexts such as recruitment and
people management. We evaluate 31 articles from top-ranked journals, scoring them based on the level
of detail and classifying their treatment of AI as either an opportunity, a threat, or both. Additionally,
we highlight the necessity of fostering a critical understanding of AI-driven decision systems among
HR professionals and stakeholders, ensuring that ethical considerations, transparency, and human
oversight remain central to AI deployment in HRM.</p>
      <p>Fairness, explainability, and human oversight are essential principles for the ethical deployment of AI
in HRM, but their application is complex and requires careful consideration of their limitations. Fairness
is a contested value shaped by organizational priorities, explainability demands cultural commitment
beyond technical solutions, and human oversight necessitates a fundamental rethink of human-machine
decision-making. While AI-driven HR systems hold the potential to improve eficiency and reduce
biases, this promise can only be realized with robust governance, continuous monitoring, and cultural
alignment within organizations to prevent reinforcing inequities.</p>
      <p>Several critical gaps remain in the application of these principles. The operationalization of fairness
requires further exploration to develop dynamic, context-sensitive frameworks [111]. Participatory
design should be integrated into AI systems to enhance explainability, ensuring transparency is
meaningful for all stakeholders [112]. Lastly, human oversight needs clearer practical guidelines, including
how to efectively train HR professionals and balance human judgment with AI recommendations.
Addressing these gaps through future research will help organizations more efectively integrate AI in
HR while ensuring ethical practices and societal trust [113].</p>
      <p>To address these shortcomings, future research should prioritize several key directions. First,
longitudinal studies are needed to examine the long-term impacts of AI-driven HRM systems on organizational
fairness, transparency, and employee trust. Such studies would provide empirical evidence to validate
or challenge current assumptions about the eficacy of these systems. Second, interdisciplinary research
involving computer science, organizational psychology, and ethics could yield innovative approaches
to integrate fairness, explainability, and oversight into AI design. Third, comparative analyzes across
industries and cultural contexts could illuminate how diferent organizational environments influence
the ethical challenges and opportunities associated with AI in HRM. Finally, the regulatory landscape
for AI in HRM requires further strengthening. Although frameworks such as the EU AI Act provide a
starting point, research should examine how regulatory compliance can be balanced with innovation,
particularly in resource-constrained settings. In addition, there is a need to investigate how global
variations in regulatory standards afect the adoption and ethical deployment of AI in multinational
organizations.</p>
      <p>In summary, enforcing an ethical usage of AI in HRM is not merely a technical or procedural endeavor;
it is a transformative process that requires organizations to reimagine their values, workflows, and
relationships with technology. By addressing the critical gaps identified in this review and advancing
new research directions, scholars and practitioners can ensure that AI serves as a tool for inclusion,
accountability, and shared prosperity in the workplace. Only through such eforts can the full potential
of AI-driven HRM be realized while protecting the dignity and rights of employees and the integrity of
organizations.</p>
    </sec>
    <sec id="sec-5">
      <title>Declarations</title>
      <p>During the preparation of this work, the authors used GPT-4o and Writefull in order to: Grammar and
spelling check. After using these tools/services, the authors reviewed and edited the content as needed
and take full responsibility for the publication’s content.
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