Emmersion
Emmersion, Rosetta Stone's assessment division within IXL Learning, sells AI-scored adaptive TrueNorth speaking and writing tests and WebCAPE reading and grammar exams. They rate language proficiency on a 0-10 scale mapped to CEFR and ACTFL and are used for pre-employment screening, checking employees' language skills and placing students.
HireAIScore rates Emmersion 44 out of 100 (grade F, Substantial gaps) under rubric v1.0, last reviewed September 25, 2026. Emmersion ranks 49 of 82 vendors rated in Assessment AI, against a category average of 46. That score is drawn from 40 evidence items across 7 rubric criteria for Emmersion — 35 with a cited source, 5 recording that nothing was located.
§ 01 - Company facts
- Legal name
- Emmersion Learning, Inc.
- Founded
- 2015
- Headquarters
- United States · US
- Pricing tier
- Mid
- Market side
- Employer-side (AEDT)
- Categories
- AssessmentScreening
- Website
- emmersion.ai
These are company details, not findings. They are editable by a verified representative and carry no weight in the score, which is built only from the cited evidence below.
§ 02 - Score breakdown
§ Score breakdown
Category scoring
Weighted contribution shown to the right of each bar.
- 01
Article 11 Technical Documentation
Weight 20%57
+11.4 · category avg 50
- 02
Bias Audit Transparency
Weight 18%28
+5.0 · category avg 41
- 03
FRIA Support
Weight 15%30
+4.5 · category avg 31
- 04
Data Governance Disclosure
Weight 15%50
+7.5 · category avg 53
- 05
Human Oversight Design
Weight 12%53
+6.4 · category avg 55
- 06
Post-Market Monitoring
Weight 12%38
+4.6 · category avg 38
- 07
Customer Documentation
Weight 8%60
+4.8 · category avg 58
Category avg is the mean raw score on that criterion across the 82 Assessment AI vendors in scope of this rubric, this one included.
§ 03 - Strongest · weakest
Strongest category
Customer Documentation
Raw score 60 · contributes 4.8 to total.
60 against a 58 category average
Weakest category
Bias Audit Transparency
Raw score 28 · contributes 5.0 to total.
28 against a 41 category average
§ 04 - Cited evidence
Download diligence record→§ Evidence
Cited per category
Every score is backed by at least one cited piece of evidence.
Evidence ledger
- Items
- 40
- Documentation
- 31
- Public statement
- 4
- Absence
- 5
- With a source URL
- 35 of 40
- Source hostnames
- 8
- Fewest items
- 4
- FRIA Support
These figures measure how thoroughly Emmersion was reviewed, not how Emmersion performed — an absence row, recording that nothing was located, is counted like any other item.
Article 11 Technical Documentation
5 items57
- DocumentationCaptured Sep 25, 2026
Emmersion's help centre publishes an Assessment Technical Reports folder: development and validation reports for its English (adaptive), Spanish, French, Italian, Japanese and Portuguese speaking tests, plus an elicited-imitation research summary, CEFR equivalency notes and proficiency-level descriptors.
https://support.emmersion.ai/support/solutions/folders/60000475587
- DocumentationCaptured Sep 25, 2026
The English Form D report (2020 adaptive version) describes adaptive item selection, EAP ability estimation, scoring through a third-party speech-recognition API and an SDCA machine-learning model built from 260 examinees (Spearman .92 with the fixed form), but it has no limitations, intended-use or subgroup section.
- DocumentationCaptured Sep 25, 2026
The Spanish Form A report documents IRT calibration on 1,040 test records (729 kept after misfit screening) and validation against ACTFL OPIc ratings for 332 records (Spearman .854).
- DocumentationCaptured Sep 25, 2026
US patent 11,488,489 (Adaptive language learning, assigned to Emmersion Learning and granted 1 November 2022) publicly describes the listen-and-repeat, automated scoring and adaptive item-selection method.
- AbsenceCaptured Sep 25, 2026
No model or system card, explainability statement, AI governance policy, ISO/IEC 42001 certificate or EU AI Act instructions for use was found on emmersion.ai, support.emmersion.ai, blog.emmersion.ai or Rosetta Stone's legal pages, and the writing test's promised technical paper is not in the technical-reports folder.
Bias Audit Transparency
8 items28
- Public statementCaptured Sep 25, 2026
The homepage markets accurate, bias-free AI scores and bias-free results for fast hiring decisions without linking any fairness study or audit.
- Public statementCaptured Sep 25, 2026
The pre-employment screening FAQ promises a 95% accuracy rate, credited to removing human error and bias, with no definition of accuracy and no supporting study.
https://www.emmersion.ai/solutions/pre-employment-language-screening/
- DocumentationCaptured Sep 25, 2026
In the Spanish technical report, predicted ACTFL levels matched actual levels 75% of the time and were within one level 95% of the time, the closest published figure to the marketed 95% accuracy.
- DocumentationCaptured Sep 25, 2026
The Portuguese technical report contains the only published fairness analysis found: an internal DIF/DTF check between Spanish-fluent and non-Spanish-fluent examinees (110 after exclusions) that flagged one item but found no significant test-level bias.
- DocumentationCaptured Sep 25, 2026
An Emmersion-funded but independently analysed May 2020 study of 128 BYU English learners found high reliability (alpha .93) but only about 0.6-0.7 agreement with ACTFL OPI and 0.82 between automatic and human scoring, both below the 0.866 threshold for aligning scores; it listed participants' first languages but did not analyse results by them.
- Public statementCaptured Sep 25, 2026
In a March 2022 interview the CEO acknowledged that speakers of some first languages carry heavier accents and said scoring deliberately tolerates pronunciation differences in favour of intelligibility, but no accent or first-language subgroup data has been published.
https://slator.com/automating-language-evaluation-with-emmersion-ceo-brigham-tomco/
- DocumentationCaptured Sep 25, 2026
Emmersion's September 2025 test-taker guidance warns that its speech recognition scores everything it hears, including background noise, so results depend on the candidate's device and surroundings.
- AbsenceCaptured Sep 25, 2026
No NYC Local Law 144 bias audit and no independent bias audit (BABL AI, DCI, ORCAA, Warden AI, Holistic AI, Credo AI or similar) was found on emmersion.ai, the support centre, the blog or Rosetta Stone pages, and trust.warden-ai.com/emmersion returns 404.
FRIA Support
4 items30
- AbsenceCaptured Sep 25, 2026
No Fundamental Rights Impact Assessment template, EU AI Act deployer guidance or discussion of candidates' fundamental rights was found on emmersion.ai, the 80-plus-article support centre, the blog or Rosetta Stone's legal and data-privacy pages.
- DocumentationCaptured Sep 25, 2026
Rosetta Stone's April 2024 DPA for enterprise and education customers names TrueNorth and WebCAPE and gives deployers GDPR processor terms and EU standard contractual clauses (Module Two), but it does not address AI-specific or fundamental-rights risks.
- DocumentationCaptured Sep 25, 2026
A public HECVAT Lite dated 1 April 2026 answers security and hosting questions a deployer could reuse, but says nothing about AI risk, bias or affected groups.
https://support.emmersion.ai/support/solutions/articles/60000694826-hecvat
- DocumentationCaptured Sep 25, 2026
The deployer guidance on cut-scores offers recommended thresholds and a custom calibration service, but no advice on job-relatedness, accommodations or effects on candidates by national origin or disability.
Data Governance Disclosure
6 items50
- DocumentationCaptured Sep 25, 2026
The attached May 2022 Security Statement says speaking-test audio is stored in US Azure regions and sent without names to third-party speech-to-text services (Carnegie Speech, IBM Watson, Google). It also says client data is kept indefinitely after contracts end with no automated deletion (deletion or anonymisation within 30 days of a written request) and backups are kept about two years.
https://support.emmersion.ai/support/solutions/articles/60000687112-emmersion-security-statement
- DocumentationCaptured Sep 25, 2026
The Terms of Use (effective 21 January 2022) state that candidates' voice recordings belong exclusively to Emmersion Learning, with a perpetual, irrevocable licence as a fallback if ownership is ever denied.
- DocumentationCaptured Sep 25, 2026
The January 2022 privacy policy covers capture of voice, screen and likeness for test integrity, gives no fixed retention period, says Emmersion typically acts as GDPR controller, and reserves the right to use or sell de-identified data.
- DocumentationCaptured Sep 25, 2026
Rosetta Stone's April 2024 DPA casts it as processor under EU SCCs, lets customer personal data be used to improve the services, makes post-contract deletion discretionary and supplies TrueNorth and WebCAPE sub-processor lists only on request.
- DocumentationCaptured Sep 25, 2026
The April 2026 HECVAT, completed by Rosetta Stone LLC, says TrueNorth and WebCAPE have had no SSAE 18/SOC 2 audit of their own (they rely on Azure's certifications, and Rosetta Stone SOC 2 coverage is planned) and links a 2019-2020 Rosetta Stone consumer privacy policy instead of Emmersion's.
https://support.emmersion.ai/support/solutions/articles/60000694826-hecvat
- DocumentationCaptured Sep 25, 2026
The English technical report names its calibration samples (a US university English programme, a refugee non-profit and overseas secondary schools) but gives no breakdown of accents or first languages.
Human Oversight Design
6 items53
- DocumentationCaptured Sep 25, 2026
Administrators see the 0.1-10.0 TrueNorth score with ACTFL and CEFR equivalents and can replay candidates' open-response recordings, so a person can check the automated result.
https://support.emmersion.ai/support/solutions/articles/60000335694-using-the-candidate-score-report
- DocumentationCaptured Sep 25, 2026
The April 2026 thresholds guide names hiring and promotions or raises as uses of the scores and recommends a two-tier scheme, with a do-not-proceed band of 0.1-6.5, for high-volume employers willing to turn away more candidates, which pushes customers toward automatic knock-outs.
- DocumentationCaptured Sep 25, 2026
The December 2025 TrueNorth scale guide cites a 6.7 score (about CEFR B2) as a common hiring minimum and suggests labelling lower scores Don't Proceed so recruiters spend no more time on those candidates.
- Public statementCaptured Sep 25, 2026
A June 2023 Emmersion hiring guide says final hiring decisions should be made by people, with AI used to gather language evidence at scale.
https://blog.emmersion.ai/humans-vs-ai-best-practices-for-bilingual-volume-hiring/
- DocumentationCaptured Sep 25, 2026
The privacy policy states that Emmersion does not currently use automated decision-making to provide its services, which leaves decisions formally with customers.
- DocumentationCaptured Sep 25, 2026
The May 2022 Security Statement says audit reports of administrator actions were not yet available and were only on the product roadmap.
https://support.emmersion.ai/support/solutions/articles/60000687112-emmersion-security-statement
Post-Market Monitoring
5 items38
- DocumentationCaptured Sep 25, 2026
Per-language version notes log scoring changes such as English C.19.04 (April 2019, tighter misfit filtering) and the adaptive D.20.09 (October 2020), but the English log has no entry after 2020.
https://support.emmersion.ai/support/solutions/articles/60000708132-english-speaking
- DocumentationCaptured Sep 25, 2026
After the adaptive release, Emmersion documented a shift in the B1-B2 score distribution and reset its TrueNorth-to-CEFR boundaries in November 2020, a real but dated example of monitoring scores after release.
- DocumentationCaptured Sep 25, 2026
The May 2021 SLA commits to 99% monthly availability, support responses within one business day via support.emmersion.ai or support@emmersion.ai, and 24 hours' notice of scheduled maintenance.
- DocumentationCaptured Sep 25, 2026
The April 2026 HECVAT reports 24x7 intrusion monitoring run by IXL, a formal incident response plan and a commitment to email affected account administrators within one business day under its continuity plan.
https://support.emmersion.ai/support/solutions/articles/60000694826-hecvat
- AbsenceCaptured Sep 25, 2026
No public status page, incident history, security.txt or vulnerability-disclosure channel was found: status.emmersion.ai and trust.emmersion.ai do not resolve, emmersion.statuspage.io redirects to Statuspage's marketing site, emmersion.ai/.well-known/security.txt returns 404, and status.ixl.com covers only IXL.
Customer Documentation
6 items60
- DocumentationCaptured Sep 25, 2026
The support centre holds 80-plus articles covering administrator setup, score interpretation, thresholds, candidate preparation, audio troubleshooting, technical reports, API documentation and a security folder.
- DocumentationCaptured Sep 25, 2026
Rosetta Stone publishes a Data Processing Addendum for enterprise and education customers that explicitly covers TrueNorth and WebCAPE.
- DocumentationCaptured Sep 25, 2026
WCAG-based accessibility conformance reports (VPAT 2.5) for TrueNorth and WebCAPE, dated November 2025, can be downloaded.
- DocumentationCaptured Sep 25, 2026
The pre-employment screening page describes supported languages, test length, the TrueNorth scale's mapping to CEFR, ACTFL and TOEFL, and anti-cheating measures.
https://www.emmersion.ai/solutions/pre-employment-language-screening/
- DocumentationCaptured Sep 25, 2026
A candidate-facing guide explains the pre-employment test and tells applicants it is designed to eliminate bias, without citing evidence.
- AbsenceCaptured Sep 25, 2026
No NYC Local Law 144, Illinois, Colorado, California or EU AI Act guidance for deployers, no candidate-notice templates and no responsible-AI page was found in the support centre, product pages or blog (dormant since July 2023).
§ 05 - Editorial notes
Company overview
Emmersion was founded in 2015. It began as an online English-tutoring company in Rexburg, Idaho, later operated from Lehi, Utah, and was bought by IXL Learning in September 2022. Its website now calls it Rosetta Stone's expert assessment division and gives a San Mateo, California address, and its April 2026 security questionnaire names Rosetta Stone LLC as the vendor. The TrueNorth speaking test uses third-party speech recognition to score listen-and-repeat items and adjusts difficulty item by item. It also records open spoken answers that administrators can play back. The writing test pairs adaptive grammar and vocabulary questions with a timed written response. Results are given on a 0-10 TrueNorth scale mapped to CEFR and ACTFL, in nine speaking languages. Contact centres and multinationals use it to screen bilingual applicants. One published case study covers 1,700 candidates screened for Computacenter in Hungary, Poland, Spain, Mexico and South Africa.
Regulatory exposure
Emmersion's own help centre lists hiring and promotions or raises among the decisions customers make with its scores, and it recommends pass/fail cut-offs for high-volume screening. Employers using TrueNorth that way are likely running an automated employment decision tool under NYC Local Law 144 (enforced since 5 July 2023), which requires an annual independent bias audit and candidate notice. DCWP has promised tougher enforcement after a December 2025 State Comptroller audit, yet no audit of TrueNorth has been published. Hiring use in Hungary, Poland and Spain falls under EU AI Act Annex III point 4, and WebCAPE student placement touches point 3. The Digital Omnibus moved those high-risk obligations to 2 December 2027 without changing them. Because the tool scores accented speech, its sharpest exposure is national-origin discrimination. Illinois' amended Human Rights Act (from 1 January 2026) requires notice of AI use and bars AI use that has a discriminatory effect. California's FEHA automated-decision rules (since 1 October 2025) sit on top of existing rules that make accent- and English-proficiency-based decisions unlawful unless job-related, and they require four-year record retention. Colorado's SB 26-189 disclosure regime and California's CPPA ADMT rules both apply from 1 January 2027. Because the test is audio-based, Illinois' AI Video Interview Act probably does not apply.
Path to a higher score
The quickest gains would come from publishing evidence rather than claims. Emmersion should commission and publish an independent bias audit. It should give impact ratios by sex and race/ethnicity for LL 144 and, more importantly for a speech test, score gaps by first language, accent, age and recording device. It should either back up or withdraw the bias-free and 95%-accuracy marketing claims. It should replace the 2019-2021 technical reports with a current model card that names the speech-recognition engines, reports error rates across accents, and states limitations and intended use. Deployers need EU AI Act guidance, a FRIA template, NYC and Illinois candidate-notice text and advice on setting job-related cut-scores. On data, Emmersion should set and publish a fixed retention period for voice recordings. It should reconcile its conflicting privacy notices, controller and processor roles and the terms' claim to own recordings, and bring TrueNorth into Rosetta Stone's SOC 2 scope. It should also add admin audit logs that customers can see, a public status page, a security contact and a maintained model-version changelog.
§ Regulatory frame
What applies to assessment ai.
Assessment is the most-regulated surface in AI hiring. NYC LL 144, EEOC and OFCCP frameworks, Illinois HB 3773, and EU AI Act Annex III §4 all apply, with overlap on bias-audit obligations.
§ Compare
Build any comparison→Emmersion against its nearest-scoring peers.
In Assessment AI.
§ Others rated in Assessment AI
All assessment vendors→Ranked 49 of 82 by weighted total under rubric v1.0. The ordering is arithmetic on the rubric and carries no view on which tool suits a given hiring process.
- 46Clevry45F
- 47Cangrade45F
- 48Equalture44F
- 49EmmersionThis profile44F
- 50Prevue HR44F
- 51Retorio44F
Conflicts of interest
No vendor pays for placement, scoring, or removal. Casework - the consulting firm that operates this directory - provides paid services to some vendors. Any active or recent (within 24 months) commercial relationship is disclosed on the affected vendor profile and the review is reassigned to an independent reviewer. See the full policy on About.
Casework has no commercial relationship with this vendor.