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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.
NYC Local Law 144, enforced since July 5, 2023, requires employers and employment agencies to:
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.
✓ Inventory all hiring tools
✓ Determine if each tool qualifies as an AEDT
Common misconception: Tools that only schedule interviews or parse resumes without scoring are NOT AEDTs. The tool must make or substantially influence employment decisions.
✓ Find a qualified independent auditor
Requirements for auditor independence:
✓ Verify auditor qualifications
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.
✓ Collect historical data
Minimum requirements:
✓ 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:
Impact ratios:
✓ Perform intersectional analysis
Required combinations (minimum 10):
✓ Create public-facing webpage
Must include:
✓ Ensure accessibility
Example URL structure:
yourcompany.com/nyc-ll144-bias-audit-2026
✓ Notice to candidates (before assessment)
Required elements:
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:
✓ Document retention
Keep for 3 years:
✓ Annual re-audit
LL144 requires audits within one year before use. Create a compliance calendar:
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.
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.
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.
Violation: Publishing results behind login, in password-protected PDFs, or without direct URL.
Solution: Create dedicated public webpage with no access barriers.
Legal requirement: Candidates can request alternative selection processes or human review.
Solution: Establish clear procedures for handling requests within 48 hours.
Target these specific, low-competition keywords:
HAIEC Compliance Platform offers:
NYC DCWP enforcement actions:
Recent enforcement trends (2025-2026):
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
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.
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.
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