Michigan started this. Now five more states have followed with their own AI-in-hiring rules. Here's what's actually required — no legal jargon, no scare tactics, just what your HR team needs to know.
Effective January 2025. Here's the short version of what it means for your hiring process.
Employers must notify candidates when an AI tool is used to assess their qualifications during hiring.
Any Michigan employer using AI or automated tools anywhere in the candidate evaluation process — screening, scoring, ranking, or interview analysis.
Clear, timely disclosure to the candidate — not a buried line in a privacy policy. If in doubt, put it in writing and give it early.
It made Michigan the first state with an AI-specific hiring disclosure requirement — and the model other states are now following.
Through 2026, five more states added their own AI-in-hiring disclosure, bias-audit, or human-review requirements.
Requires disclosure and, in many cases, candidate consent before AI is used to analyze video interviews.
New responsible-AI rules require notice when AI substantially informs a hiring decision, and restrict discriminatory use.
Treats hiring tools as "high-risk" AI systems — requiring impact assessments, documented bias mitigation, and notice to candidates.
New automated-decision-making rules give applicants notice, access, and opt-out rights around AI-driven hiring tools.
Regulatory guidance confirms employers can be liable for AI-driven hiring bias — pushing audits and human review into standard practice.
Illustrative overview as of 2026 — requirements, effective dates, and enforcement details vary and change. Always confirm current requirements with counsel before relying on this for a compliance decision. Want the interactive version? See our state-by-state compliance map.
Most AI consultancies treat compliance as a footnote — something legal handles after the tools are already in place. We built our entire engagement model around it, starting with the state that moved first. That means we're not learning these requirements as they land; we've been tracking them since Michigan's law took effect.
For HR teams, that's the difference between a consultant who can install a tool and one who can tell you whether you should — and how to prove, if asked, that a human was in the loop the whole time.
Start with our Governance Policy Workshop, or just get on a call and we'll map the fastest path.
Tell us where your HR team stands today, and we'll help you map the fastest path to a compliant, confident AI rollout.
