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Job-matching platforms, careers services, AI and the Equality Act in Great Britain

Updated

Much of the work of finding a job now runs through software: platforms that match CVs to vacancies, services that rank candidates for employers, careers and training providers that recommend courses or routes. In Great Britain, section 55 of the Equality Act 2010 puts duties on anyone concerned with providing an "employment service", separate from the duties on the employer who finally hires. This page explains what the sections say and how they bear on AI tools.

The short answer: an employment service-provider must not discriminate against, harass or victimise people in deciding who gets the service, on what terms, by refusing or ending it, or by any other detriment (s55). The definition of an employment service in s56 includes services for finding employment for people and services for supplying employers with people to do work, as well as vocational training and guidance.

What counts as an employment service

For section 55, the provision of an employment service includes (s56(2)):

  • providing vocational training or vocational guidance, or making arrangements for either;
  • providing a service for finding employment for persons;
  • providing a service for supplying employers with persons to do work;
  • services under arrangements made under section 2 or section 10 (careers services) of the Employment and Training Act 1973, and certain functions of Scottish Enterprise;
  • an assessment related to the conferment of a relevant qualification within section 53, except where the assessment is by the qualifications body that confers it (for that body, see qualifications bodies).

"Vocational training" means training for employment, or work experience, including work experience whose length is not agreed until after it begins (s56(6)). A reference to training includes facilities for training (s56(8)).

Whether a particular job board, matching app or CV tool is "a service for finding employment for persons" or "for supplying employers with persons to do work" depends on what it actually does. A platform whose purpose is to find people jobs, or to find employers workers, can fall within those words, whether the matching is done by staff or by software. The Act describes the service, not the technology used to deliver it.

What a service-provider must not do

An employment service-provider must not discriminate against a person (s55(1)):

  • in the arrangements it makes for selecting who to provide, or offer to provide, the service to;
  • as to the terms on which it offers to provide the service;
  • by not offering to provide the service.

In providing the service, it must not discriminate against a person (s55(2)):

  • as to the terms on which it provides the service;
  • by not providing the service;
  • by terminating the service;
  • by subjecting the person to any other detriment.

It must not harass a person who asks for the service or a person for whom it provides the service (s55(3)). It must not victimise a person in the same ways it must not discriminate (s55(4) and (5)); see victimisation.

Where AI tools come in

  • Who is offered the service: a rule or model that decides which users are shown vacancies, invited to apply or put forward to employers is part of the "arrangements" for selecting persons to whom the service is offered.
  • Terms of the service: different visibility, ranking or features for different users are about the terms on which the service is provided.
  • Not providing or ending the service: automatic removal, suspension or deprioritising of profiles can amount to not providing or terminating the service, or to another detriment, depending on the facts.
  • Chatbots and messages: automated messages to users are still provided "in relation to the provision" of the service, so the harassment duty can apply to them as it would to messages from staff.

The tests for what counts as discrimination, such as direct and indirect discrimination and the protected characteristics, are in other parts of the Act; see AI and the Equality Act.

Reasonable adjustments

A duty to make reasonable adjustments applies to an employment service-provider, except in relation to the provision of a vocational service (s55(6)). For a vocational service, the duty in section 29(7)(a), the reasonable adjustments duty on providers of services to the public, applies instead, and a failure to comply with it is treated as a contravention of Part 5 for enforcement purposes (s55(7); s29(7)).

A "vocational service" here means vocational training (but not work experience), vocational guidance, arranging either, and services for finding employment for persons, which for this purpose also include services for assisting persons to retain employment (s56(7)). So a job-finding platform and a careers guidance service can sit under the section 29(7)(a) duty, while a service supplying employers with workers sits under the section 55(6) duty. For disabled users of AI tools, see AI and disabled workers.

What the sections do not cover

  • Training or guidance to which another provision of Part 5 applies (s56(3)).
  • Training or guidance for pupils of a school covered by section 85, so far as the school's responsible body has power to afford access to it (s56(4)).
  • Training or guidance for students of an institution covered by section 91, so far as its governing body has power to afford access to it (s56(5)).

Practical steps

  • Platforms and careers services: list each automated step that decides who sees what, who is put forward and whose profile is limited, and check each against the duties above. Keep a route for users to ask for a person to review a decision and to ask for adjustments.
  • Recruitment agencies: section 55 sits alongside the conduct rules for agencies; see recruitment agency rules. If a client asks for a set-up that would discriminate, see instructing or helping discrimination.
  • Job seekers and learners: if a platform or careers service refused, limited or ended your use of it, the duty sits with the service-provider, not only with the employers it works for. Ask what the decision was based on.

For hiring tools used by employers themselves, see AI in hiring. This page covers Great Britain and is general information on the law as at 2 November 2026, not legal advice.

Questions and answers

Does the Equality Act apply to job boards and AI job-matching platforms?

Section 55 applies to anyone concerned with providing an employment service, which section 56 defines to include a service for finding employment for persons and a service for supplying employers with persons to do work. Whether a given platform is covered depends on what it does, not on whether it uses AI.

What must an employment service-provider not do?

It must not discriminate against, harass or victimise people in its arrangements for selecting who gets the service, in the terms of the service, by not offering or providing it, by ending it, or by any other detriment.

Do employment service-providers have to make reasonable adjustments?

Yes. Section 55(6) applies a reasonable adjustments duty, except for vocational services such as vocational training, vocational guidance and job-finding services, where the section 29(7)(a) duty applies instead under section 55(7).

Is school or university careers guidance covered?

Section 56 excludes training or guidance for pupils of schools covered by section 85, and for students of institutions covered by section 91, so far as the school or institution has power to afford access to it.

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