From the State Government edition of October 19, 2026
Kentucky Personnel Memo 26-09 bars AI from reviewing applications, screening candidates or making selection decisions in Executive Branch hiring, while allowing non-decision HR drafting uses
Kentucky Personnel Cabinet (Secretary Mary Elizabeth Bailey); Commonwealth Office of Technology · State workforce and hiring (AI use policy) · Kentucky
- Publisher
- Kentucky Personnel Cabinet
- Original publication
- 2026-05-19
- Source retrieved
- 2026-10-20
- Event date
- 2026-05-19
What happened
Kentucky's Personnel Cabinet directed, effective immediately on May 19, 2026, that AI tools are not approved for reviewing applications, screening candidates or making selection decisions in Executive Branch hiring, citing potential discriminatory bias against protected classes and equal employment opportunity law. HR staff may use AI for non-decision tasks: drafting job postings and position descriptions, template letters, summarizing non-confidential data and sample interview questions, under COT policy CIO-126. Entering applicant data, PII or other sensitive records into any AI tool is prohibited, and the rules will be added to statewide hiring training. Why now: California's Oct 19 launch of applicant-side GenAI job matching makes the line between helping applicants and screening them a live design question for other states.
Why it matters
It is a clear, citable state control that separates permitted HR drafting uses from prohibited selection uses, a template other HR departments and CIOs can adapt as AI hiring tools spread.
Evidence and measured results
Policy text only; no incident or bias finding is cited as the trigger. Permitted and prohibited uses and the data-entry ban are stated directly in the memo.
Limitations and uncertainty
Issued May 19, 2026, before this stream's recent runs; included for its relevance to the Oct 19 California launch. Enforcement method, monitoring and exceptions are not described. The memo applies to the Executive Branch.
Put this evidence to work
Lighthouse Advisory interpretation, grounded in this source. Enriched 2026-10-19; this does not change the original publication date. Each role follows the same checklist so takeaways compare across sources.
Sales
Role takeaway
- Customer problem
- HR departments want AI help but face bias and equal employment risk in hiring decisions.
- Stakeholders
- State personnel secretary
- Agency HR administrators
- State CIO and AI policy coordinator
- General counsel
- Hiring managers
- Discovery questions
- Which HR tasks do staff already use AI for?
- Do your applicant-tracking tools include AI ranking or scoring features?
- How would you verify those features stay disabled?
- What training covers AI in hiring today?
- Value hypothesis
- A permitted-use playbook and vendor-feature review may let HR teams use AI for drafting while staying within a no-screening policy; no time savings are measured in this source.
- Potential engagement
- Four-week HR AI compliance review: inventory AI features in HR systems, draft a permitted-use playbook and training content, and recommend configuration controls.
- Unsupported claims
- That AI screening tools are proven biased
- That the policy reduced discrimination
- Any productivity gain from permitted uses
Pre-sales engineering
Role takeaway
- Fit
- States with central HR platforms and an AI policy office able to set configuration standards.
- Architecture and integration
- Configuration review of applicant-tracking and HR suites to disable AI screening; approved drafting tools kept separate from applicant data; data-loss prevention rules for PII.
- Prerequisites
- Inventory of HR systems and their AI features
- Approved AI tool list under state policy
- Data-loss prevention capability
- Training platform access
- Constraints
- Vendor updates can add AI features
- Applies to Executive Branch only
- State civil service and EEO law vary
- Monitoring method not specified
- Security
- Block applicant PII and sensitive records from AI tools through policy and technical controls; log AI tool use in HR contexts.
- Proof of value
- Confirm screening features are disabled in each HR system
- Test that PII cannot be pasted into approved AI tools
- Sample HR AI use for compliance
Delivery
Role takeaway
- Work
- Operationalize a no-AI-screening rule with a permitted-use playbook, configuration controls and training.
- Dependencies
- Personnel cabinet policy owner
- State CIO AI policy
- HR system vendors
- Training team
- Ownership
- State personnel cabinet, with agency HR administrators accountable for compliance.
- Skills and adoption
- Train HR staff and interview panels on permitted versus prohibited uses with worked examples.
- Governance checkpoints
- Annual vendor feature review
- Training completion tracking
- Exception and question log review
- Policy refresh as tools change
- Acceptance criteria
- Proposed: all HR systems documented with screening features disabled
- Proposed: hiring-process staff training completion tracked toward full coverage
- Proposed: periodic sample finds no applicant PII in AI tools
- Risks
- Shadow AI use in screening
- Vendor features enabled by default
- Policy too broad to allow helpful applicant-side tools
- No monitoring to detect breaches
Implementation considerations
Lighthouse Advisory interpretation across the operating dimensions a public-sector buyer must settle before this evidence becomes a design. Each note answers the question under its heading for this specific source.
Architecture and integration
What must connect, and where does the AI sit in the workflow?
HR systems and any AI features added by applicant-tracking vendors need a way to disable ranking, scoring or screening functions, and AI tools used for drafting must not be connected to applicant records.
Governance
Who approves, reviews and stays accountable for outcomes?
Defines a decision boundary (no AI in review, screening or selection) and assigns compliance to all staff in the hiring process, with training updates. Agencies still need inventory and monitoring to confirm vendor features do not reintroduce screening.
Security and privacy
What data, permissions and controls need testing?
Prohibits entering applicant data, PII, Social Security numbers, medical information or other sensitive records into any AI tool, regardless of tool approval status.
Accessibility and workforce
Who is affected, and what skills or accommodations follow?
Protects applicants from untested automated screening; HR staff still need training on permitted uses so the rule does not suppress helpful drafting work.
Procurement
What should contracts, pricing and exit terms secure?
HR technology contracts should let the state disable AI ranking and screening features and require notice before new AI features are enabled.
Operating model
Which teams own the service once it runs?
Decision authority in hiring stays with people; AI is confined to support tasks, which keeps accountability clear.
Publication history
- 2026-10-19State Government · Issue 424 resources
Stable resource ID: kentucky-personnel-memo-26-09-bars-ai-in-application-review-screening-selection-20260519