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.
§ 01 — Score breakdown
§ Score breakdown
Category scoring
Weighted contribution shown to the right of each bar.
- 01
Article 11 Technical Documentation
Weight 20%62
+12.4
- 02
Bias Audit Transparency
Weight 18%58
+10.4
- 03
FRIA Support
Weight 15%38
+5.7
- 04
Data Governance Disclosure
Weight 15%60
+9.0
- 05
Human Oversight Design
Weight 12%60
+7.2
- 06
Post-Market Monitoring
Weight 12%35
+4.2
- 07
Customer Documentation
Weight 8%60
+4.8
§ 02 — Strongest · weakest
Strongest category
Article 11 Technical Documentation
Raw score 62 · contributes 12.4 to total.
Weakest category
Post-Market Monitoring
Raw score 35 · contributes 4.2 to total.
§ 03 — Cited evidence
§ Evidence
Cited per category
Every score is backed by at least one cited piece of evidence.
§ 04 — Editorial notes
Company overview
Bullhorn, Inc. (founded 1999, headquartered in Boston, US; owned by Insight Partners since 2017) is the leading ATS/CRM platform for staffing and recruitment agencies, used by more than 10,000 firms. Its AI layer spans Bullhorn Copilot and the Bullhorn Amplify suite (Amplify Chat, Digital Workers) plus Search & Match and parsing technology acquired with Textkernel in 2024, which source, screen, rank and match candidates to jobs. Pricing is quote-based and runs roughly $99 to $315+ per user per month with custom enterprise contracts and large implementation fees, placing it at the higher end of the market.
Regulatory exposure
Bullhorn's matching/ranking AI (AI Automatch, Search & Match) functions as an automated employment decision tool, exposing it to NYC Local Law 144, the EU AI Act's Annex III high-risk hiring category, Illinois and Colorado AI-employment rules wherever its customers operate. Bullhorn is notably more forthcoming than most peers: it engaged the respected independent auditor ORCAA to test AI Automatch for bias under LL 144, signed the EU AI Pact, and maintains a structured technical-documentation pack referencing the NIST AI Risk Management Framework. The central gap is publication: the ORCAA bias audit and the technical pack are available only on request through an account manager, the audit does not appear on public LL 144 trackers, and there is no FRIA template or public post-market monitoring channel.
Path to a higher score
Bullhorn could materially raise its score by publishing the ORCAA bias-audit summary as a downloadable document (with auditor, date, distribution date and intersectional metrics) and committing to annual public re-audits, and by posting its technical-documentation pack or model/system cards publicly rather than gating them behind account managers. Adding explicit EU AI Act Article 27 FRIA deployer guidance and NYC LL 144 candidate-notice templates, a public AI changelog or post-market monitoring page, and pursuing ISO 42001 certification would move it from a credibly-governed-but-gated posture toward genuine public transparency.
Conflicts of interest
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