NYC LL144 vs EU AI Act
Side-by-Side Comparison
NYC LL144 is narrower (hiring only) with lower penalties but already enforced. EU AI Act is comprehensive but not yet in effect. Here's the detailed comparison.
Detailed Comparison
10 key aspects compared side-by-side.
| Aspect | NYC Local Law 144 | EU AI Act | Simpler |
|---|---|---|---|
| Scope | Hiring & promotion only | All AI systems (4 risk levels) | |
| Who Covered | Employers + employment agencies in NYC | Providers + Deployers + Importers (EU-wide) | |
| Effective Date | July 5, 2023 (already enforced) | Aug 2, 2026 (phased) | |
| Max Penalty | $1,500 per violation | €35M or 7% global revenue | |
| Audit Required | Yes, annual bias audit | Conformity assessment (high-risk) | TIE |
| Independent Auditor | Required | Required (notified bodies) | TIE |
| Cure Period | No cure period | No cure period | TIE |
| Candidate Notice | Required before use | Transparency obligations | TIE |
| Public Disclosure | Audit results must be public | Registration in EU database | |
| Documentation | 8 documents | 15+ documents |
💡 Key Takeaway
NYC LL144 is significantly simpler than EU AI Act. NYC focuses only on hiring AI with $1,500 max penalty, while EU covers all AI systems with up to €35M fines. However, NYC is already enforced (since 2023) while EU doesn't take effect until 2026.
Which Law Applies to You?
You Need NYC LL144 If:
- You're an employer or employment agency in NYC
- You use AI for hiring or promotion decisions
- You need to comply NOW (law already in effect)
You Need EU AI Act If:
- You provide or deploy AI systems in the EU
- Your AI affects EU citizens (any domain)
- You have until Aug 2026 to prepare (phased rollout)
⚠️ Both Laws May Apply
If you use hiring AI in NYC AND operate AI systems in the EU, you need to comply with BOTH laws. They have different scopes, requirements, and penalties. EU AI Act is far more comprehensive and expensive to comply with.
Comply With Both Regulations
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