Staffing & HR services. Candidates are customers too.
The rules now check how they are judged.
Staffing and recruitment firms, executive search, HR-tech and payroll providers, gig-work platforms and assessment companies, matching people to work under India’s new labour codes and, where AI screens candidates, under new AI rules. We build candidate and client journeys, compliant job and vacancy flows, payroll and worker apps for the 2026 rules, and AI screening that is audited and decided by people.
DPDP Act 2023 — Digital Personal Data Protection Act, 2023GDPR — General Data Protection Regulation (EU) 2016/679EU AI Act — Artificial Intelligence Act (EU) 2024/1689NIST AI RMF 1.0 — AI Risk Management FrameworkISO/IEC 27001:2022 — Information security management systemsWCAG 2.2 AA — Web Content Accessibility Guidelines
Staffing & HR servicesCandidates are customers too.
ClaimsAdvertising & claims: Sometimes shapes the work
RegulatorSector regulator: Shapes most of the work
PaymentsPayments: Often shapes the work
DataPersonal data: Shapes most of the work
SecuritySecurity & incidents: Often shapes the work
AccessAccessibility: Sometimes shapes the work
AIAI governance: Shapes most of the work
What is shifting
The codes changed the contract, and AI rules reached the shortlist.
Four labour codes took effect, vacancy reporting went digital, and recruitment AI became high-risk in the EU and audited in New York. Each shift names what it demands, with a fact you can check.
Every interview is a judgement on both sides of the table.
01
Four labour codes replaced 29 laws.
It demandsContracts, payroll and worker journeys rebuilt around one set of definitions.
SignalThe Code on Wages, the Industrial Relations Code, the Code on Social Security and the OSH Code took effect on 21 November 2025, replacing 29 central labour laws.
02
Vacancy reporting went digital.
It demandsJob-posting flows that report vacancies to career centres as the rules require.
SignalThe Social Security (Central) Rules of 8 May 2026 have private employers with 20 or more staff report vacancies at least 15 days before applications close.
03
AI screening is high-risk in the EU.
It demandsScreening tools with documentation, bias testing and human decisions.
SignalAI used in recruitment is high-risk under Annex III of the EU AI Act; the Digital Omnibus of July 2026 set those duties to apply from 2 December 2027.
04
Automated hiring tools are audited in New York City.
It demandsBias audits and candidate notices built into the product for US clients.
SignalNew York City’s Local Law 144 requires a bias audit in the year before an automated employment decision tool is used, plus candidate notices; enforced since 5 July 2023.
The rulebook
Every hire has a contract, every algorithm an audit.
The four labour codes and their 2026 rules, contract-labour licensing, overseas recruitment, the data law and the AI rules for hiring, read for a staffing or HR business. Your counsel keeps sign-off.
Frameworks we build to
DPDP Act 2023 — Digital Personal Data Protection Act, 2023
GDPR — General Data Protection Regulation (EU) 2016/679
EU AI Act — Artificial Intelligence Act (EU) 2024/1689
NIST AI RMF 1.0 — AI Risk Management Framework
ISO/IEC 27001:2022 — Information security management systems
WCAG 2.2 AA — Web Content Accessibility Guidelines
Frameworks we design and build to — not a claim of certification.
Sector regulator
Shapes most of the work
Ministry of Labour and Employment
The four labour codes
In force since 21 November 2025: appointment letters for every worker, equal pay and no sex discrimination in recruitment, fixed-term workers with equal benefits and gratuity after a year, and single registration and licensing.
We designOffer letters, contracts and onboarding are rebuilt on the codes’ terms, with the evidence kept.
Code on Wages, 2019 · IR Code, 2020 · Code on Social Security, 2020 · OSH Code, 2020 · in force 21 November 2025 Official text: The four labour codes↗
Ministry of Labour and Employment
Social Security (Central) Rules, 2026 — vacancies and gig workers
Private establishments with 20 or more employees report vacancies to career centres at least 15 days before applications close; aggregators register gig and platform workers on the central portal in real time or daily.
We designJob-posting and onboarding flows report to the career centre and the portal as they happen, with an audit trail.
Social Security (Central) Rules, 2026 · G.S.R. 344(E), 8 May 2026
Ministry of Labour and Employment
OSH Code, 2020 — contract labour licensing
Contractors employing 50 or more contract workers need a licence, valid for five years, with a single all-India licence available for work in several states.
We designClient and worker portals show the licence and the deployment it covers.
CVs, assessments and background checks are personal data: collected for a stated purpose with consent, kept only while the purpose lasts and erased when it ends, from 13 May 2027.
We designConsent per purpose, retention timers and a candidate-facing way to withdraw.
AI used to target job ads, filter applications or evaluate candidates is high-risk (Annex III, point 4) from 2 December 2027; inferring emotions at work has been banned since 2 February 2025.
We designScreening tools ship with documentation, bias tests, human review and logs, and never analyse emotions in interviews.
Employers and employment agencies may not use an automated employment decision tool without a bias audit in the past year, a public summary of it and notices to candidates.
We designFor US clients, bias-audit summaries and candidate notices are built into the hiring flow.
Compiled 3 October 2026. Our reading of typical programmes, not legal advice. Rules change; your counsel confirms how each one applies to you.
Challenges
Your customers’ problems, and your own.
What we hear in almost every staffing & HR services brief — on the customer’s side of the screen, and on yours.
AYour customers
A1
Apply once, hear back
Candidates want a short application, a status and an answer.
A2
Fair, and explained
Screening that a candidate could understand and challenge.
A3
Paid right, on time
Contract and gig workers paid correctly, with their benefits visible.
Offers now come with a code behind them.
BYour operation
B1
New codes, old contracts
Appointment letters, fixed-term terms, contributions and registrations updated across thousands of workers.
B2
Data on every candidate
CVs, assessments and background checks held lawfully and deleted on time.
B3
AI that can be audited
Every automated step documented, tested for bias and reviewed by a person.
What we build
Six disciplines, weighted for staffing & HR services.
A typical programme here draws on each discipline in this mix. Every line names what it builds for the industry and links to the capability that does the work.
Each use case is tested for bias and for instructions hidden in CVs, keeps a log, and no model rejects a candidate.
Use case 01
Shortlisting assistant
Measured bySelection-rate ratio across groups on the bias test
Tested forOWASP LLM01 · Prompt injection
agent / shortlisting-assistantGuarded
TaskRanks applications against the documented criteria for a role and explains each ranking.
GuardrailUses job-related criteria only, never protected traits or their proxies; ignores instructions hidden in CVs; bias-tested before each use.
HumanA recruiter decides every shortlist and rejection.
LogCriteria, rankings, explanations and the recruiter’s decision.
✓Ships only with its evaluation set, its guardrail and an owner
Use case 02
Candidate status assistant
Measured byCandidate queries resolved without a call
Tested forOWASP LLM02 · Sensitive information disclosure
agent / candidate-status-assistantGuarded
TaskAnswers candidates’ questions about their application, the next step and timelines.
GuardrailReports recorded status only and never gives a decision or feedback the recruiter has not approved.
HumanRecruiters own every decision and every piece of feedback.
LogQuestions and answers, per candidate.
✓Ships only with its evaluation set, its guardrail and an owner
Use case 03
Job ad checker
Measured byAds approved at first check
Tested forOWASP LLM05 · Improper output handling
agent / job-ad-checkerGuarded
TaskChecks job ads for discriminatory wording and for missing pay or vacancy-reporting details before posting.
GuardrailFlags only: it cannot post or edit a live ad.
HumanThe hiring manager approves each ad.
LogAds checked, flags and approvals.
✓Ships only with its evaluation set, its guardrail and an owner
Work and insights
The work, anonymised until clients approve.
Projects in this industry are published once a client approves the write-up. Until then, here is what we have written on the rules that apply.
A typical programme · composite
A staffing firm rebuilt its candidate journey with a one-page application, status updates and a person reviewing every automated shortlist, and moved its appointment letters and contributions onto the new codes’ terms.
Anonymised and illustrative: the shape a programme takes, never a named client.
Related reading
Nothing published on staffing & HR services yet. Ask us what we are seeing in the industry.
The codes have applied since 21 November 2025. We redesign offer letters, onboarding, payroll records and worker communication on the codes’ terms and the rules notified under them; your counsel confirms each change.
Q.02Can we use AI to screen candidates?
Yes, with care: documented criteria, bias tests before use, logs and a person deciding every shortlist. For EU clients it is high-risk AI under the AI Act from 2 December 2027; for New York City roles a bias audit and candidate notices are required.
Q.03Do you build gig-work platforms?
Yes: worker onboarding, earnings, benefits and registration on the government portal, designed with workers and built for the 2026 rules.
Q.04How long can we keep CVs?
Only as long as the purpose needs and the law allows. We build retention timers, consent per purpose and a way for candidates to withdraw; your counsel sets the periods.
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