Equalture

Company overview

Equalture B.V. is a Rotterdam-based HR-tech company (registered address Mauritsweg 35, Rotterdam; Dutch Chamber of Commerce no. 69620172) founded by twin sisters Charlotte Melkert (CEO) and Fleur Melkert (CCO), with Jaap Haagmans as CTO. Its product replaces CV screening with short neuroscience-derived games — typically 15 to 45 minutes, available in 14 languages — that measure cognitive abilities and behavioural tendencies from gameplay rather than self-report. Employers first have incumbent staff play the games to build a role-specific "Success Profile" (marketed as Top-Performer Signal Mapping and a Success DNA Engine), enriched with industry benchmarks; candidates are then scored and ranked against that profile, with results pushed into roughly eighteen named ATS integrations including Workday, SAP SuccessFactors, Greenhouse, SmartRecruiters, Lever and Teamtailor. Named customers include DHL Express, VodafoneZiggo, Ahold Delhaize, Rituals, Van Lanschot Kempen, G4S and Politie Nederland.

Regulatory exposure

Equalture is an EU-established provider of an AI system used for the recruitment and selection of natural persons, placing it squarely in Annex III point 4 of the EU AI Act and making it the archetypal high-risk provider facing Article 9 risk management, Article 10 data governance, Article 11 technical documentation, Article 13 transparency, Article 14 human oversight, Article 15 accuracy and Article 72 post-market monitoring duties, while its EU employer customers face Article 26 deployer duties and Article 27 FRIAs. Dutch and EU data protection law applies directly: the privacy policy sets a 12-month retention period for assessment results, discloses possible transfers outside the EEA and states that "No personal decisions are made solely by automated processing," a GDPR Article 22 posture though the Article is never cited. US exposure appears minimal — no US office, NYC Local Law 144 bias audit, Illinois AI Video Interview Act or Colorado SB 24-205 material was found anywhere on the site. The striking gap is that a full crawl of the company's page sitemap (~90 pages) and post sitemaps (~557 URLs) plus the Sprinto-hosted trust centre surfaced zero references to the EU AI Act, high-risk classification, conformity assessment or CE marking, and no AI-specific policy among the 47 governance policies published in the trust centre.

Path to a higher score

The fastest gains are ungating what already exists: the Science Manual and the "validation studies" the science page invites visitors to request should be published as free downloads, and the Neurodiversity and Inclusion Report should show its actual findings — sample sizes, subgroup pass rates and effect sizes — rather than only stating its aim. Beyond that, Equalture should publish a genuine adverse-impact report covering assessment scores (not just candidate satisfaction ratings) broken down by gender, age, ethnicity and disability status, name the independent party behind the "independent validation" claim in its FAQ, and commission a dated third-party algorithmic audit from a recognised auditor with a downloadable report. On the regulatory side it needs an Article 11 technical-documentation pack and instructions-for-use for deployers, Article 27 FRIA guidance for its EU employer customers, an explicit statement of the human-oversight and override controls in the product, and ISO/IEC 42001 or an equivalent AI management-system policy added alongside its ISO 27001 certification. Finally, a public status page, a model and product changelog, and a named security disclosure contact would move post-market monitoring from a support inbox to a real public surface.