New York City's Local Law 144 (LL144) represents the first mandatory bias audit requirement for automated employment decision tools (AEDTs) in the United States. If your organization uses AI for hiring, screening, or promotion decisions in NYC, compliance isn't optional—it's the law.

This guide provides a practical, actionable checklist to help HR teams, compliance officers, and business leaders navigate LL144 requirements without legal jargon or complexity.

What is NYC Local Law 144?

NYC Local Law 144, enforced since July 5, 2023, requires employers and employment agencies to:

Conduct annual independent bias audits of any automated employment decision tool
Publish audit results publicly on their website
Provide notice to candidates and employees before using AEDTs
Allow alternative selection processes for those who opt out

Key Definition: An AEDT is any computational process that substantially assists or replaces discretionary decision-making for employment decisions, including screening resumes, ranking candidates, or predicting job performance.

The Essential NYC LL144 Compliance Checklist

Phase 1: Identify Your AEDTs (Week 1)

✓ Inventory all hiring tools

Resume screening software (e.g., Greenhouse, Lever with AI features)
Video interview platforms with AI scoring (e.g., HireVue, Spark Hire)
Chatbots conducting initial screenings
Predictive analytics for candidate ranking
Skills assessment tools with automated scoring

✓ Determine if each tool qualifies as an AEDT

Does it use machine learning or statistical models?
Does it substantially assist hiring decisions?
Is it used for NYC-based positions?

Common misconception: Tools that only schedule interviews or parse resumes without scoring are NOT AEDTs. The tool must make or substantially influence employment decisions.

Phase 2: Engage an Independent Auditor (Weeks 2-3)

✓ Find a qualified independent auditor

Requirements for auditor independence:

No financial interest in your company
Not involved in developing or distributing the AEDT
No conflict of interest

✓ Verify auditor qualifications

Experience with bias testing methodologies
Understanding of EEOC's four-fifths rule
Familiarity with NYC DCWP regulations

Pro tip: The NYC Department of Consumer and Worker Protection (DCWP) doesn't maintain an approved auditor list. You're responsible for vetting auditor qualifications.

Phase 3: Conduct the Bias Audit (Weeks 4-8)

✓ Collect historical data

Minimum requirements:

At least 12 months of historical data
Minimum sample sizes: 100 individuals per category (gender, race/ethnicity)
If insufficient data, use test data that reflects NYC demographics

✓ Calculate selection rates

For each protected category:

Selection Rate = (Number Selected / Number Screened) × 100

✓ Compute impact ratios

Impact Ratio = (Selection Rate for Category / Highest Selection Rate)

Example calculation:

White candidates: 200/400 = 50% selection rate
Black candidates: 120/300 = 40% selection rate
Hispanic candidates: 90/200 = 45% selection rate
Asian candidates: 55/100 = 55% selection rate (highest)

Impact ratios:

White: 50% ÷ 55% = 0.91 ✓
Black: 40% ÷ 55% = 0.73 ⚠️ (Below 0.80 threshold)
Hispanic: 45% ÷ 55% = 0.82 ✓

✓ Perform intersectional analysis

Required combinations (minimum 10):

Male + each race/ethnicity (5 groups)
Female + each race/ethnicity (5 groups)

Phase 4: Publish Results (Week 9)

✓ Create public-facing webpage

Must include:

Date of audit
Selection rates for each category
Impact ratios for each category
Number of individuals in each category
Distribution date (when results were published)

✓ Ensure accessibility

No login required
Direct URL (not behind paywall)
Available for at least 6 months after last use of AEDT

Example URL structure: yourcompany.com/nyc-ll144-bias-audit-2026

Phase 5: Provide Candidate Notice (Ongoing)

✓ Notice to candidates (before assessment)

Required elements:

Statement that AEDT will be used
Job qualifications and characteristics the AEDT will assess
Link to publicly available bias audit results

Sample notice:

"This employer uses an automated employment decision tool (AEDT) to assist in evaluating candidates for this position. The tool assesses [specific qualifications]. You can review the bias audit results at [URL]. For questions or to request an alternative selection process, contact [email/phone]."

✓ Notice to employees (at least 10 days before use)

For promotions or internal transfers:

Written notice via email or posting
Same information as candidate notice
Alternative process option

Phase 6: Maintain Compliance Records (Ongoing)

✓ Document retention

Keep for 3 years:

Bias audit reports
Auditor qualifications and independence verification
Candidate/employee notices
Alternative process requests and responses
AEDT vendor contracts

✓ Annual re-audit

LL144 requires audits within one year before use. Create a compliance calendar:

Month 1: Begin auditor search
Month 9: Complete audit
Month 10: Publish results
Month 11: Update candidate notices
Month 12: Prepare for next cycle

Common Compliance Mistakes to Avoid

Mistake #1: Assuming vendor compliance is enough

Reality: Even if your AEDT vendor provides audit results, YOU are responsible for compliance. The employer, not the vendor, faces penalties for violations.

Solution: Obtain vendor audit results but verify they meet NYC requirements. Conduct your own audit if vendor results are insufficient.

Mistake #2: Using outdated audit results

Penalty risk: $500 per day for first violation, $1,500 per day for subsequent violations.

Solution: Set calendar reminders 11 months after each audit to begin renewal process.

Mistake #3: Incomplete intersectional analysis

Common error: Only testing gender and race separately, not combinations.

Solution: Test all 10 minimum intersections (5 race/ethnicity × 2 genders). Use test data if historical data lacks sufficient sample sizes.

Mistake #4: Hiding audit results

Violation: Publishing results behind login, in password-protected PDFs, or without direct URL.

Solution: Create dedicated public webpage with no access barriers.

Mistake #5: Ignoring alternative process requests

Legal requirement: Candidates can request alternative selection processes or human review.

Solution: Establish clear procedures for handling requests within 48 hours.

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Tools to Simplify NYC LL144 Compliance

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Automated AEDT inventory and classification
Bias audit calculation tools
Public results page generator
Candidate notice templates
Compliance calendar with automated reminders

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Enforcement and Penalties

NYC DCWP enforcement actions:

First violation: $500/day civil penalty
Subsequent violations: $1,500/day civil penalty
Complaints investigated within 60 days
Public enforcement actions published

Recent enforcement trends (2025-2026):

47% of complaints involve missing candidate notices
31% involve outdated or missing bias audits
22% involve failure to provide alternative processes

Next Steps

Week 1: Complete AEDT inventory using our free assessment tool

Week 2: Request proposals from 3 independent auditors

Week 3: Review vendor AEDT contracts for compliance gaps

Month 2: Begin bias audit with selected auditor

Month 3: Publish results and update candidate notices

Frequently Asked Questions

Q: Do we need separate audits for each AEDT? A: Yes, each distinct AEDT requires its own bias audit unless they use identical algorithms and training data.

Q: What if we only use AEDTs for non-NYC positions? A: You're exempt from LL144, but document your geographic restrictions to demonstrate non-applicability.

Q: Can we use the same auditor annually? A: Yes, as long as they maintain independence (no financial interest in your company or the AEDT vendor).

Q: What happens if our audit shows bias? A: Publication is still required. You must either remediate the bias, discontinue the AEDT, or accept the compliance risk. The law doesn't prohibit biased tools—only requires transparency.

Conclusion

NYC Local Law 144 compliance requires systematic planning, independent auditing, and ongoing documentation. While the requirements are specific, they're achievable with proper preparation.

The key is starting early—don't wait until your current audit expires. Build compliance into your hiring operations from day one.

Ready to simplify NYC LL144 compliance? Try HAIEC's automated compliance platform free for 14 days →

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