§ The result
1 point separates Gem and Bullhorn.
Gem (Sourcing) edges Bullhorn (ATS-integrated) by 1 point under rubric v1.0, 55 to 54. Gem leads 4 of the 7 criteria, including Bias Audit Transparency, while Bullhorn leads 3, including Article 11 Technical Documentation. Gem takes the heaviest weighted swing, Bias Audit Transparency at 18% (Bullhorn 58, Gem 66), which is 46% of the weighted advantage Gem holds; the widest raw gap is a different criterion, Post-Market Monitoring, Bullhorn 35 to Gem 47.
Vendor profile
Bullhorn
Bullhorn is a cloud-based applicant tracking system and CRM for staffing and recruiting agencies, with AI features (Bullhorn Copilot/Amplify, automation, and Textkernel-powered search and match) that source, screen, and rank candidates against jobs.
Vendor profile
Gem
Gem is an AI-first recruiting platform combining a talent CRM, AI sourcing and outreach automation, candidate engagement, and a newer applicant tracking system with AI-powered application review and ranking.
§ The record
Bullhorn is filed under ATS-integrated AI, Gem under Candidate sourcing AI. They also share 1 secondary category: Screening.
Both are in scope of EU AI Act, NYC LL 144, Colorado AI Act and Illinois HB 3773.
| Record | Bullhorn | Gem |
|---|---|---|
| Price tier | High | High |
| Headquarters | US | US |
| Founded | 1999 | 2017 |
§ What decides it
The criteria that move the gap, heaviest swing first.
18% weight · 30% of the movement so far
Bias Audit Transparency
Bullhorn 58 · Gem 66
1.4 weighted points to Gem
12% weight · 59% of the movement so far
Post-Market Monitoring
Bullhorn 35 · Gem 47
1.4 weighted points to Gem
20% weight · 76% of the movement so far
Article 11 Technical Documentation
Bullhorn 62 · Gem 58
0.8 weighted points to Bullhorn
15% weight · 85% of the movement so far
FRIA Support
Bullhorn 38 · Gem 35
0.4 weighted points to Bullhorn
15% weight · 94% of the movement so far
Data Governance Disclosure
Bullhorn 60 · Gem 57
0.4 weighted points to Bullhorn
8% weight · 98% of the movement so far
Customer Documentation
Bullhorn 60 · Gem 62
0.2 weighted points to Gem
12% weight · 100% of the movement so far
Human Oversight Design
Bullhorn 60 · Gem 61
0.1 weighted points to Gem
Weighted delta is the raw difference times the criterion weight, so the 7 figures above sum to -1.5 — the difference between the two totals before either is rounded. Shares are of 4.9 points of movement counted without direction. The table below rounds each side to a whole number first, so its Δ raw total reads -1 beside that -1.5.
§ Category-by-category
Raw score per criterion, with weighted delta.
Δ is Bullhorn minus Gem.
| Category | Weight | Bullhorn | Gem | Δ raw | Δ weighted |
|---|---|---|---|---|---|
| Article 11 Technical Documentation | 20% | 62 | 58 | +4 | +0.8 |
| Bias Audit Transparency | 18% | 58 | 66 | -8 | -1.4 |
| FRIA Support | 15% | 38 | 35 | +3 | +0.4 |
| Data Governance Disclosure | 15% | 60 | 57 | +3 | +0.4 |
| Human Oversight Design | 12% | 60 | 61 | -1 | -0.1 |
| Post-Market Monitoring | 12% | 35 | 47 | -12 | -1.4 |
| Customer Documentation | 8% | 60 | 62 | -2 | -0.2 |
| Total | 100% | 54 (F) | 55 (F) | -1 | -1.5 |
§ Evidence
Cited sources and documented absences, criterion by criterion.
An absence is a finding, not a blank: the reviewer looked for a named artefact and recorded that it is not located. Where a source sits is a fact about hosting only.
| Criterion | Weight | Bullhorn | Gem | ||||
|---|---|---|---|---|---|---|---|
| Cited | Absences | Audit / hosting | Cited | Absences | Audit / hosting | ||
| Article 11 Technical Documentation | 20% | 2 | 1 | Sources on the vendor's own domain | 2 | 1 | Audit reportSources on the vendor's own domainSources on a separate domain |
| Bias Audit Transparency | 18% | 3 | 1 | Audit reportSources on the vendor's own domain | 3 | 0 | Audit reportSources on the vendor's own domainSources on a separate domain |
| FRIA Support | 15% | 1 | 1 | — | 2 | 1 | Sources on the vendor's own domain |
| Data Governance Disclosure | 15% | 3 | 0 | Sources on the vendor's own domain | 3 | 0 | Audit reportSources on the vendor's own domain |
| Human Oversight Design | 12% | 2 | 1 | Sources on the vendor's own domain | 3 | 0 | Audit reportSources on the vendor's own domainSources on a separate domain |
| Post-Market Monitoring | 12% | 1 | 1 | Sources on the vendor's own domain | 3 | 0 | Sources on the vendor's own domain |
| Customer Documentation | 8% | 3 | 1 | Sources on the vendor's own domain | 3 | 0 | Sources on the vendor's own domain |
| All criteria | 100% | 15 | 6 | Audit reportSources on the vendor's own domain | 19 | 2 | Audit reportSources on the vendor's own domainSources on a separate domain |
Bullhorn has 20 evidence rows across 7 of 7 criteria — 15 with a source URL, 6 documented absences; Gem has 21 evidence rows across 7 of 7 criteria — 19 with a source URL, 2 documented absences; some documentation or audit rows for Gem sit on a domain separate from the vendor's own site.
Provenance
The scores above are documented by 41 evidence rows on file for these two vendors: 20 for Bullhorn, across 2 distinct source domains, and 21 for Gem, across 2 distinct source domains.
- Rubric
- v1.0
- Bullhorn last reviewed
- June 7, 2026 · HireAIScore editorial team
- Gem last reviewed
- June 7, 2026 · HireAIScore editorial team
HireAIScore scores are editorial research, not legal advice, and no vendor pays for placement, scoring or removal — see the methodology, conflicts policy and terms.
§ Where next