DefeatedHB 2094 (2025)Virginia

Virginia High-Risk Artificial Intelligence Developer and Deployer Act for HR & Hiring

How Virginia High-Risk Artificial Intelligence Developer and Deployer Act applies to hr & hiring organizations and the obligations to plan for.

Effective
July 1, 2026
Max penalty
$10K
Applies to
developer + deployer

Why this law matters for hr & hiring

Employers and HR-tech vendors using AI for screening resumes, scoring candidates, conducting video interviews, or making employment-related consequential decisions.

This law applies to hr hiring organizations to the extent their AI use falls within the law's scope (see the obligations below). Organizations operating in Virginia should treat this law as part of the baseline regulatory obligations alongside any sector-specific federal rules.

Recommended next steps

  1. Inventory AI systems used in hr & hiring workflows that may fall within Virginia High-Risk Artificial Intelligence Developer and Deployer Act's scope.
  2. Map each system against the obligations above and identify the responsible role (developer vs deployer).
  3. Adopt a structured framework — see NIST AI RMF and ISO/IEC 42001 — to demonstrate due care and produce audit-ready evidence.
  4. Document obligations satisfied and gaps in a single register, refreshed at the cadence required by the law (typically annual).
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