Vendor Requirements

Working With Vendors
What to Ask & Expect

Most AEDT vendors provide bias audits. But you must verify compliance.

Key Questions
6
Vendor Duties
4
Audit Cost
$5-15K
Frequency
Annual

Vendor Responsibilities

What vendors should provide for LL144 compliance

VEN-1

Provide Bias Audit

ยง20-870(b)(1)

Description

Most AEDT vendors include annual bias audit in their service. Verify audit meets NYC requirements before relying on it.

Loophole

Vendor audit must be by independent auditor. If vendor conducts own audit, employer needs separate independent audit.

Strategy

Ask vendor: "Is your auditor independent per NYC LL144?" Get written confirmation.

VEN-2

Audit Documentation

ยง20-870(b)(2)

Description

Vendor should provide all required audit elements: selection rates, impact ratios, data sources, auditor info.

Loophole

Vendor may provide partial audit. Employer responsible for ensuring all elements present.

Strategy

Use checklist of 8 required elements. Don't accept incomplete audits.

VEN-3

Update Frequency

ยง20-870(b)(1)

Description

Vendor must provide updated audit annually. Employer responsible for tracking expiration.

Loophole

Vendor may not automatically renew. Employer must request renewal.

Strategy

Set calendar reminder 60 days before audit expires. Request renewal early.

VEN-4

Audit Cost

Commercial

Description

Some vendors include audit in base price. Others charge $5K-$15K extra annually.

Loophole

Negotiate audit inclusion in contract. Many vendors will include if asked.

Strategy

Ask: "Can you include LL144 audit in our contract?" Often works for enterprise clients.

6 Questions to Ask Every Vendor

Use this checklist when evaluating AEDT vendors

1

Is your bias audit conducted by an independent auditor?

Why Ask This

NYC requires independent auditor. Vendor self-audits don't count.

๐Ÿšฉ Red Flag

If vendor says "we audit ourselves" - NOT compliant.

2

Does your audit test all EEOC categories plus intersections?

Why Ask This

NYC requires testing sex, race/ethnicity, and all intersections (e.g., Black Female).

๐Ÿšฉ Red Flag

If vendor only tests sex and race separately - NOT compliant.

3

Will you provide audit summary with all 8 required elements?

Why Ask This

Employer must publish complete summary. Partial audits create compliance gaps.

๐Ÿšฉ Red Flag

If vendor says "we provide high-level summary" - may be incomplete.

4

How often do you update the audit?

Why Ask This

NYC requires audit within 12 months of use. Annual renewal is standard.

๐Ÿšฉ Red Flag

If vendor says "audit valid for 2+ years" - NOT compliant.

5

Is the audit cost included or extra?

Why Ask This

Budget planning. Audits can cost $5K-$15K annually.

๐Ÿšฉ Red Flag

Hidden audit fees are common. Get pricing in writing.

6

Can we use your audit for our public disclosure?

Why Ask This

Employer must publish audit results. Need vendor permission to publish.

๐Ÿšฉ Red Flag

If vendor says "audit is confidential" - compliance problem.

๐Ÿ’ก Pro Tip

Get vendor compliance commitments in writing. Add LL144 compliance clause to your contract requiring vendor to provide compliant bias audit annually.

Sample clause: "Vendor shall provide annual bias audit compliant with NYC Local Law 144, conducted by independent auditor, testing all EEOC categories and intersections."

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