Lucca AI Transparency Index: Germany's Top Employers Lag

German employers are increasingly using AI to screen job applications, but many are not telling candidates about it. That is the finding of the new AI Transparency Index from HR software provider Lucca, which examined the 25 largest German employers by headcount.

Recruiters are struggling with a flood of applications, partly because AI tools can produce cover letters and CVs in seconds and lower the barrier to applying. Many HR departments are now responding with AI of their own.

Allianz leads, Aldi Nord trails

Lucca assessed four areas: legal transparency in applicant privacy notices, openness about AI use during the application process, transparency about the recruiting software in use, and company-wide AI governance, including policies, ethics codes and business, sustainability and human rights reports. A maximum of 30 points was available.

Allianz scored highest with 26 points. Deutsche Telekom and SAP share second place with 20 points each. Siemens Energy is second to last with five points, and Aldi Nord finishes last with just one.

According to Lucca, 21 of the 25 companies use application software that at least in theory supports AI functions. Only four, Bayer, SAP, Allianz and Siemens, communicate those functions openly. At most other firms, applicants can learn about AI only through the privacy notice.

"Our study shows that AI has arrived in many companies' systems, but is often only visible to applicants in the privacy policy," said Marek Kraus, Country Manager Germany at Lucca. In the medium term, he argued, AI use should be disclosed where applicants actually look for information.

What applicants can do

Lucca advises job seekers to read the privacy notice, which sets out what personal data is processed. Terms such as "automated processing" or vaguer wording like "pre-selection" can point to AI use.

Applicants who spot this early can adapt. Lucca suggests weaving keywords and requirements from the job posting into the CV and cover letter so automated systems pick them up faster. That only makes sense, the company notes, if candidates genuinely have the qualifications.