Hard red line RL4
Emotion Recognition in Workplace or Education
The product uses emotion recognition in a workplace or educational setting.
T1 — Prohibited practice
Why this red line exists
The sharpest single fact in the underlying research: this is not merely "high-risk" — it is a prohibited practice outright, medical/safety exceptions aside. It quietly implicates a lot of mundane HR and edtech tooling.
Laws that reference it
- EU AI Act — Art.5(1)(f) — prohibits emotion recognition in workplace and educational institutions directly, not just as an Annex III high-risk domain.
- EU AI Act — Annex III (High-Risk Systems) — the fallback domain-based tier when the Art.5 prohibition does not apply; obligations apply from 2027-12-02.
- Illinois BIPA — voiceprint and facial-geometry data used for emotion inference is squarely biometric identifier data under this statute.