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Is emotion recognition at work banned in the EU?

The system being classified

You deploy a system that infers the emotional state of employees — from video, voice or keystrokes — during their work.

Verdict

Prohibited practice

One or more selected practices are banned outright under Article 5. Deployment in the EU must stop; continuing exposes you to the maximum fine tier.

2 applicable obligations
Maximum fine tier: €35,000,000 or 7% of global annual turnover
Key date: Article 5 prohibitions in force since 2 February 2025 (non-consensual intimate imagery: from 2 December 2026)

This is the classification of the configuration described above, not of your system. One different answer can move it — which is exactly what the comparison further down shows, and what the free assessment settles in about ten minutes.

What produced this verdict

These are the entire inputs. The engine is deterministic, so these answers always produce the verdict above.

Article 5 practices

  • · Emotion recognition in workplaces or education

Scope and role

  • · Deployer — you use it under your own authority
  • · Placed on the EU market, or output used in the EU
  • · Used in a workplace toward workers

What applies, and from when (2)

Every entry cites the article it comes from and the date it binds. That second column is the part most summaries of the Omnibus get wrong.

ArticleObligationBinding from
Art. 4
AI literacy
Ensure staff dealing with AI systems have a sufficient level of AI literacy (training records recommended).
2 February 2025
Best practice
AI system inventory
Maintain a central register of all AI systems in use, their purpose, risk tier and owner.
Good practice

What would change this verdict

Each row below is the same scenario with one answer changed, re-run through the same engine. These are not predictions about your system; they are what our classifier returns when that single fact differs. Where one change to the scenario necessarily moves a second answer with it, the row says which, and why.

The system is used for medical or safety reasons instead

Becomes high-risk system

Article 5(1)(f) carves out medical and safety purposes. The carve-out is narrow and the burden of showing it sits with you, which is why the engine flags rather than decides it.

Two answers move together here: Clearing the prohibition without saying where the system then lands would publish a minimal-risk verdict for something still watching workers, so the Annex III worker-management answer moves with it.

  • Obligations: 29 (+7)
  • Key date changes to 2 December 2027 — Annex III high-risk obligations apply (postponed from 2 August 2026 by the 2026 Omnibus)

Your system is not this system

The assessment asks the same questions this page answered for a generic configuration, and produces the verdict, the gap list and the 30-day plan for yours. Ten minutes, free, no sign-up, and it runs entirely in your browser — your answers never reach us.

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Other configurations

Produced by rule set 1.6.1, legal state 2026-08-05. The engine is deterministic and contains no language model in the verdict path, and every rule is published at /methodology for you to audit.

AnnexWise is preparation software, not legal advice. This page classifies a described configuration; it is not an opinion on any particular organisation or system.