Who's Exempt?
Exemptions Explained
NYC Local Law 144 has very few exemptions. Most AI hiring tools are covered.
Exemption Status by Category
Click each category to see detailed explanation and loopholes
Small Employers
NOT EXEMPTExplanation
No small employer exemption. Law applies to ALL employers and employment agencies using AEDTs in NYC, regardless of size.
Loophole/Caveat
None. Even single-employee companies must comply if using AEDT.
Internal Promotions Only
NOT EXEMPTExplanation
Law covers both hiring AND promotion decisions. Internal-only AEDTs must comply.
Loophole/Caveat
None. Promotions are explicitly covered under §20-870(a).
Manual Review After AI
NOT EXEMPTExplanation
If AI provides score/recommendation that influences decision, it's an AEDT even with human review.
Loophole/Caveat
None. Human-in-the-loop doesn't exempt you if AI influences decision.
Basic ATS (No Scoring)
EXEMPTExplanation
Applicant tracking systems that ONLY organize/store applications without scoring/ranking are exempt.
Loophole/Caveat
If your ATS has ANY scoring, ranking, or recommendation feature, it's an AEDT.
Junk Email Filters
EXEMPTExplanation
Tools that only filter spam/junk emails are exempt per DCWP guidance.
Loophole/Caveat
But if filter uses AI to assess candidate quality (not just spam), it's an AEDT.
Scheduling Tools
EXEMPTExplanation
Calendar/scheduling tools that don't assess candidates are exempt.
Loophole/Caveat
If tool recommends interview times based on candidate assessment, may be AEDT.
Remote Candidates
NOT EXEMPTExplanation
Law applies to candidates for NYC positions, regardless of candidate location.
Loophole/Caveat
None. If job is in NYC, law applies even if candidate is remote.
Contract Workers
NOT EXEMPTExplanation
Law covers employment agencies placing contract workers. Must comply.
Loophole/Caveat
None. Contractors and temps are covered.
⚠️ Key Takeaway
NYC Local Law 144 has VERY FEW exemptions. If your tool scores, ranks, or recommends candidates in any way, it's likely an AEDT and must comply.
When in doubt, assume compliance is required. The penalties for non-compliance ($500-$1,500 per candidate) far exceed the cost of a bias audit.
Not Sure If You're Exempt?
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