SF Compass · Open source

AI agents in SAP SuccessFactors, governed like workers

Agents already validate payroll, screen applications and answer employee queries. Almost nobody records them where work is planned, costed and governed. This is a data model and validator that does, with every check mapped to the EU AI Act.

What you get

  • An effective-dated cust_DigitalWorker MDF object design with owner, kill-switch owner, position, cost centre and expiring permissions
  • 15 CHK-AGT checks with console, JSON and HTML output and a CI-friendly exit code
  • Decision scopes mapped to Annex III point 4 and the Article 5 prohibitions
  • A 36-item audit workbook for HR, deployer and provider obligations
15validation checks
55automated tests
0runtime dependencies
2 Dec 2027HR high-risk rules apply

Why not create agents as employees?

It is the obvious shortcut and it breaks four things at once.

  • Headcount and statutory reporting. Agents inflate FTE, gender pay gap denominators and workforce analytics.
  • Payroll replication. EC Payroll and third-party payroll integrations pick up employment records. An agent with a job record is a payroll defect waiting to happen.
  • Licensing. Many HCM licences count employee records.
  • Meaning. Contract, notice and leave fields fill with junk.

The model instead

Agents get their own object that references the same foundation data, positions and people as employees, so they show up in org, cost and capacity views without polluting employment data.

Plus a composite cust_AgentPermission child with mandatory expiry, and references to legal entity and cost centre.

EU AI Act dates for HR, as amended

Regulation (EU) 2026/1744 (the Digital Omnibus on AI) was published on 24 July 2026 and entered into force on 27 July 2026.

2 Feb 2025Prohibitions apply, including workplace emotion recognition (Art. 5(1)(f))
2 Aug 2026Transparency duties apply, such as telling people they are talking to an AI (Art. 50)
2 Dec 2027Annex III high-risk obligations apply to employment uses, deferred from 2 Aug 2026

The CHK-AGT check catalogue

IDSeverityRuleBasis
CHK-AGT-00ERRORRequired fields, enumerations and dates validData quality
CHK-AGT-01ERRORAccountable owner is an active employeeArt. 26(2)
CHK-AGT-02ERRORKill-switch owner is an active employeeArt. 14(4)(e)
CHK-AGT-03ERROREmployment decision scopes force high-risk classificationAnnex III point 4; Art. 6(3)
CHK-AGT-04ERRORHigh-risk agent has a human oversight modeArt. 14; Art. 26(2)
CHK-AGT-05ERRORHigh-risk agent keeps logs for at least six monthsArt. 26(6)
CHK-AGT-06ERRORWorkers' representatives informed on or before go-liveArt. 26(7)
CHK-AGT-07ERRORPermissions expire within 365 days of grantLeast privilege
CHK-AGT-08ERRORNo permission active past its expiry, including on suspended agentsLeast privilege
CHK-AGT-09ERRORAssigned position is active and staffed AGENT or HYBRIDPosition control
CHK-AGT-10ERRORCost centre exists in foundation dataCost allocation
CHK-AGT-11WARNINGPeriodic review not overdueGovernance
CHK-AGT-12ERRORNo overlapping effective-dated recordsData integrity
CHK-AGT-13WARNINGOwner not accountable for more agents than they can overseeOversight capacity
CHK-AGT-14ERRORNo active prohibited practiceArt. 5(1)(f)

"High-risk" means declared high-risk or carrying an employment decision scope, so a misclassification cannot hide the oversight, logging and consultation gaps behind it.

Run it in a minute

git clone https://github.com/SahirVhora/sf-agent-workforce
cd sf-agent-workforce
python -m agent_workforce.validate \
  examples/demo_with_findings.json \
  --as-of 2026-10-10 --html report.html
python -m pytest -q

Python 3.10+, standard library only. Exit code 0 means clean, 1 means errors, 2 means unreadable input.

Free download: EU AI Act HR audit checklist

A working Excel checklist for HR and HRIS teams: 36 requirements with article references and applicable dates, a triage of 12 common HR AI use cases, and a summary that tracks completion by area.

Questions

Should AI agents be created as employees in SuccessFactors?

No. Creating agents as users with job records inflates headcount and statutory reporting, risks payroll replication, can consume per-employee licences and fills employment fields with meaningless data. Model them as their own effective-dated MDF object that references positions, cost centres and accountable people.

When do the EU AI Act high-risk rules apply to HR systems?

From 2 December 2027 for stand-alone Annex III systems, including employment and workers' management, under Regulation (EU) 2026/1744. Prohibitions have applied since 2 February 2025 and Article 50 transparency duties since 2 August 2026.

Does the EU AI Act apply to UK employers?

It can. Article 2 brings providers and deployers outside the EU into scope where they place AI systems on the EU market or where the system's output is used in the EU, for example an HR system used for EU-based workers or candidates.

Which HR uses of AI are high-risk?

Annex III point 4 covers recruitment and selection (targeted job adverts, filtering applications, evaluating candidates) and decisions affecting terms of work, promotion, termination, task allocation based on individual behaviour or traits, and monitoring or evaluating performance and behaviour.

Part of the SF Compass transformation assurance suite.