§ The result
2 points separate Bullhorn and Phenom.
Bullhorn (ATS-integrated) edges Phenom (Sourcing) by 2 points under rubric v1.0, 54 to 52. Bullhorn leads 4 of the 7 criteria, including FRIA Support, while Phenom leads 1, including Bias Audit Transparency, and 2 are level. Bias Audit Transparency is at once the widest raw gap and the heaviest weighted swing, and it belongs to Phenom — Bullhorn 58, Phenom 75, on an 18% weight — which is 100% of the weighted advantage Phenom holds across the 1 criterion on that side of the table.
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
Phenom
Talent experience platform combining a career site CMS, candidate CRM, internal mobility, and conversational AI for screening and scheduling.
§ The record
Bullhorn is filed under ATS-integrated AI, Phenom 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 | Phenom |
|---|---|---|
| Price tier | High | Enterprise |
| Headquarters | US | US |
| Founded | 1999 | 2010 |
§ What decides it
The criteria that move the gap, heaviest swing first.
18% weight · 41% of the movement so far
Bias Audit Transparency
Bullhorn 58 · Phenom 75
3.1 weighted points to Phenom
15% weight · 68% of the movement so far
FRIA Support
Bullhorn 38 · Phenom 25
1.9 weighted points to Bullhorn
20% weight · 87% of the movement so far
Article 11 Technical Documentation
Bullhorn 62 · Phenom 55
1.4 weighted points to Bullhorn
12% weight · 95% of the movement so far
Post-Market Monitoring
Bullhorn 35 · Phenom 30
0.6 weighted points to Bullhorn
8% weight · 100% of the movement so far
Customer Documentation
Bullhorn 60 · Phenom 55
0.4 weighted points to Bullhorn
Weighted delta is the raw difference times the criterion weight, so the 5 figures above sum to +1.3 — the difference between the two totals before either is rounded. Shares are of 7.4 points of movement counted without direction. The table below rounds each side to a whole number first, so its Δ raw total reads +2 beside that +1.3.
§ Category-by-category
Raw score per criterion, with weighted delta.
Δ is Bullhorn minus Phenom.
| Category | Weight | Bullhorn | Phenom | Δ raw | Δ weighted |
|---|---|---|---|---|---|
| Article 11 Technical Documentation | 20% | 62 | 55 | +7 | +1.4 |
| Bias Audit Transparency | 18% | 58 | 75 | -17 | -3.1 |
| FRIA Support | 15% | 38 | 25 | +13 | +1.9 |
| Data Governance Disclosure | 15% | 60 | 60 | - | - |
| Human Oversight Design | 12% | 60 | 60 | - | - |
| Post-Market Monitoring | 12% | 35 | 30 | +5 | +0.6 |
| Customer Documentation | 8% | 60 | 55 | +5 | +0.4 |
| Total | 100% | 54 (F) | 52 (F) | +2 | +1.3 |
§ 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 | Phenom | ||||
|---|---|---|---|---|---|---|---|
| Cited | Absences | Audit / hosting | Cited | Absences | Audit / hosting | ||
| Article 11 Technical Documentation | 20% | 2 | 1 | Sources on the vendor's own domain | 2 | 0 | Sources on the vendor's own domain |
| Bias Audit Transparency | 18% | 3 | 1 | Audit reportSources on the vendor's own domain | 2 | 0 | Audit reportSources on the vendor's own domain |
| FRIA Support | 15% | 1 | 1 | — | 0 | 1 | — |
| Data Governance Disclosure | 15% | 3 | 0 | Sources on the vendor's own domain | 1 | 0 | Sources on the vendor's own domain |
| Human Oversight Design | 12% | 2 | 1 | Sources on the vendor's own domain | 1 | 0 | — |
| Post-Market Monitoring | 12% | 1 | 1 | Sources on the vendor's own domain | 0 | 1 | — |
| Customer Documentation | 8% | 3 | 1 | Sources on the vendor's own domain | 2 | 0 | Sources on the vendor's own domain |
| All criteria | 100% | 15 | 6 | Audit reportSources on the vendor's own domain | 8 | 2 | Audit reportSources on the vendor's own domain |
Bullhorn has 20 evidence rows across 7 of 7 criteria — 15 with a source URL, 6 documented absences; Phenom has 10 evidence rows across 7 of 7 criteria — 8 with a source URL, 2 documented absences.
Provenance
The scores above are documented by 30 evidence rows on file for these two vendors: 20 for Bullhorn, across 2 distinct source domains, and 10 for Phenom, across 1 distinct source domain.
- Rubric
- v1.0
- Bullhorn last reviewed
- June 7, 2026 · HireAIScore editorial team
- Phenom last reviewed
- May 21, 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