§ The result
Gem leads Loxo on all 7 criteria.
Gem finishes 18 points clear of Loxo inside the Sourcing cohort under rubric v1.0: 55 against 37. Gem leads every one of the 7 criteria, Loxo none of them, and the closest of the 7 is Customer Documentation, Gem 62 to Loxo 58. Bias Audit Transparency is both the widest raw gap and the heaviest weighted swing — Gem 66, Loxo 20 — and at an 18% weight it carries 46% of the weighted advantage Gem holds across the 7 criteria on that side of the table.
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.
Vendor profile
Loxo
Loxo is an AI-native talent-intelligence platform that combines candidate sourcing, a recruiting CRM, and an applicant tracking system, using proprietary ranking models and a self-built talent graph of 800M+ people to source, rank, and match candidates for recruiting and staffing firms.
§ The record
Gem and Loxo are both filed under Candidate sourcing AI. They also share 1 secondary category: ATS-integrated.
Both are in scope of EU AI Act, NYC LL 144 and Colorado AI Act. Only Gem is in scope of Illinois HB 3773.
| Record | Gem | Loxo |
|---|---|---|
| Price tier | High | Mid |
| Headquarters | US | US |
| Founded | 2017 | 2012 |
§ What decides it
The criteria that move the gap, heaviest swing first.
18% weight · 46% of the movement so far
Bias Audit Transparency
Gem 66 · Loxo 20
8.3 weighted points to Gem
20% weight · 76% of the movement so far
Article 11 Technical Documentation
Gem 58 · Loxo 30
5.6 weighted points to Gem
12% weight · 84% of the movement so far
Human Oversight Design
Gem 61 · Loxo 50
1.3 weighted points to Gem
15% weight · 89% of the movement so far
Data Governance Disclosure
Gem 57 · Loxo 50
1.1 weighted points to Gem
12% weight · 94% of the movement so far
Post-Market Monitoring
Gem 47 · Loxo 40
0.8 weighted points to Gem
15% weight · 98% of the movement so far
FRIA Support
Gem 35 · Loxo 30
0.8 weighted points to Gem
8% weight · 100% of the movement so far
Customer Documentation
Gem 62 · Loxo 58
0.3 weighted points to Gem
Weighted delta is the raw difference times the criterion weight, so the 7 figures above sum to +18.2 — the difference between the two totals before either is rounded. Shares are of 18.2 points of movement counted without direction. The table below rounds each side to a whole number first, so its Δ raw total reads +18 beside that +18.2.
§ Category-by-category
Raw score per criterion, with weighted delta.
Δ is Gem minus Loxo.
| Category | Weight | Gem | Loxo | Δ raw | Δ weighted |
|---|---|---|---|---|---|
| Article 11 Technical Documentation | 20% | 58 | 30 | +28 | +5.6 |
| Bias Audit Transparency | 18% | 66 | 20 | +46 | +8.3 |
| FRIA Support | 15% | 35 | 30 | +5 | +0.8 |
| Data Governance Disclosure | 15% | 57 | 50 | +7 | +1.1 |
| Human Oversight Design | 12% | 61 | 50 | +11 | +1.3 |
| Post-Market Monitoring | 12% | 47 | 40 | +7 | +0.8 |
| Customer Documentation | 8% | 62 | 58 | +4 | +0.3 |
| Total | 100% | 55 (F) | 37 (F) | +18 | +18.2 |
§ 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 | Gem | Loxo | ||||
|---|---|---|---|---|---|---|---|
| Cited | Absences | Audit / hosting | Cited | Absences | Audit / hosting | ||
| Article 11 Technical Documentation | 20% | 2 | 1 | Audit reportSources on the vendor's own domainSources on a separate domain | 2 | 1 | Sources on the vendor's own domain |
| Bias Audit Transparency | 18% | 3 | 0 | Audit reportSources on the vendor's own domainSources on a separate domain | 1 | 1 | — |
| FRIA Support | 15% | 2 | 1 | Sources on the vendor's own domain | 1 | 1 | Sources on the vendor's own domain |
| Data Governance Disclosure | 15% | 3 | 0 | Audit reportSources on the vendor's own domain | 3 | 1 | Audit reportSources on the vendor's own domain |
| Human Oversight Design | 12% | 3 | 0 | Audit reportSources on the vendor's own domainSources on a separate domain | 1 | 1 | — |
| Post-Market Monitoring | 12% | 3 | 0 | Sources on the vendor's own domain | 2 | 1 | Sources on the vendor's own domain |
| Customer Documentation | 8% | 3 | 0 | Sources on the vendor's own domain | 2 | 1 | Sources on the vendor's own domain |
| All criteria | 100% | 19 | 2 | Audit reportSources on the vendor's own domainSources on a separate domain | 12 | 7 | Audit reportSources on the vendor's own domain |
Gem has 21 evidence rows across 7 of 7 criteria — 19 with a source URL, 2 documented absences; Loxo has 19 evidence rows across 7 of 7 criteria — 12 with a source URL, 7 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 40 evidence rows on file for these two vendors: 21 for Gem, across 2 distinct source domains, and 19 for Loxo, across 1 distinct source domain.
- Rubric
- v1.0
- Gem last reviewed
- June 7, 2026 · HireAIScore editorial team
- Loxo last reviewed
- July 17, 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
Scored against