Multinational employers now face at least four distinct approaches to regulating AI in the workplace, each with its own definitions, audit requirements, and enforcement triggers.
Despite the differences in form, every framework converges on the same expectation: AI may assist an employment decision, but a human must remain accountable for it.
Frances M. Green and Francesco Rotondi co-authored "The Common Thread in the Tapestry of Global AI Laws: Employee Protection," published in Databird Business Journal, comparing how the United States, the European Union, Italy, and China regulate AI-driven hiring, monitoring, and workforce decisions.
Frances M. Green, Of Counsel at Epstein Becker Green, counsels multinational employers on AI governance, cybersecurity, and data privacy compliance. Francesco Rotondi, Founding Name Partner of LabLaw Studio Legale Rotondi & Partners advises Italian and multinational companies on labor law, industrial relations, and corporate reorganizations.
The Q&A walks through recruitment screening under the EU AI Act and GDPR, and Italy's Legislative Decree No. 152/1997 and Law No. 132/2025. It also covers China's Personal Information Protection Law and the U.S. patchwork of disclosure and audit duties. Those include Illinois's biometric privacy statute, New York City's Local Law 144 bias audits, and the EEOC's position that Title VII reaches AI-driven decisions regardless of new legislation. Frances and Francesco also address a pending California class action against Meta Platforms alleging AI-assisted layoff selection. They also cover Italy's Workers' Statute protections, which require employee-representative agreement or Labour Inspectorate authorization before deploying workplace monitoring tools. Employers are urged to inventory their AI systems, question vendor bias-testing claims, and build documented human review into every AI-assisted decision. As Frances puts it, the goal is to "design 'decision workflows' in which the AI informs, and a human decides."
Epstein Becker Green Staff Attorney Ann W. Parks contributed to the preparation of this article.
Get in Touch
To learn more about this topic, contact Frances Green at fgreen@ebglaw.com.
