# 4. Does the EU AI Act affect a US scouting department?


**Potentially, but the connection must be established rather than inferred from the nationality of a player or supplier.** Article 2 covers, among other situations, EU-established deployers and third-country providers or deployers where system outputs are used in the EU. That makes shared recruitment models within an ownership group a specific review priority. ([ai-act-service-desk.ec.europa.eu](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-2))

Annex III lists AI intended for recruitment or selection, candidate evaluation, certain work-related decisions and worker-performance monitoring. A supplier’s precise intended purpose matters: do not classify every statistical database or video search engine identically. ([ai-act-service-desk.ec.europa.eu](https://ai-act-service-desk.ec.europa.eu/en/ai-act/annex-3))

The **27 July 2026 AI Omnibus** moved the Annex III high-risk application date to **2 December 2027**. It is an enacted change, not merely the earlier proposal. The AI Act also expressly preserves the application of relevant EU data-protection legislation. ([digital-strategy.ec.europa.eu](https://digital-strategy.ec.europa.eu/en/news/ai-omnibus-enters-force))

**Recommended multi-club licence stress test:**

1. Identify every entity using the system and every country in which outputs inform decisions.
2. Separate supplier, integrator and club responsibilities.
3. Obtain the supplier’s intended-use and classification rationale.
4. Require model-version records, change notices and access to relevant documentation.
5. Review permission to share underlying data, inferred scores and reports separately.

An enterprise account is not an adequate substitute for this entity-and-workflow map.