What is NYC Local Law 144?

NYC Local Law 144 (effective July 5, 2023) requires employers and employment agencies using an automated employment decision tool (AEDT) to substantially assist or replace discretionary decisions about NYC-based candidates or employees to: (1) commission an independent bias audit within the prior year, (2) publish the audit summary on the employer's website, and (3) notify candidates that an AEDT will be used at least 10 business days before use.

What counts as an AEDT under NYC LL 144?

An AEDT is a computational process derived from machine learning, statistical modeling, data analytics, or AI that issues simplified outputs (a score, classification, or recommendation) used to substantially assist or replace discretionary decision-making. Resume screeners, interview scoring tools, and ranking algorithms typically qualify.

Who must conduct the bias audit?

An 'independent auditor' — a person or group not involved in using, developing, or distributing the AEDT and with no employment or financial relationship with the employer or vendor that would impair independence.

How often must the bias audit be performed?

Annually. The audit summary must be no more than one year old at the time the AEDT is used to evaluate a candidate.

Home › Compliance › NYC Local Law 144

NYC Local Law 144: the 2026 compliance guide for hiring teams

Q: What are the penalties for non-compliance?

Civil penalties of $500 for the first violation and $500 to $1,500 for each subsequent violation. Each day of non-compliance and each candidate not properly notified can constitute a separate violation.

If you hire in New York City and use any AI, machine-learning, or statistical tool to screen, score, or rank candidates, NYC Local Law 144 applies to you. Here's exactly what it requires, what counts as an AEDT, what the bias audit must contain, and a practical checklist to be defensible.

The 60-second version NYC Local Law 144 took effect July 5, 2023. It requires (1) an annual independent bias audit of every AEDT used to assess NYC candidates, (2) public posting of the audit summary on the employer's careers site, and (3) candidate notice at least 10 business days before the AEDT is used. Penalties are per-violation and per-day. The DCWP enforces.

What the law actually says

NYC Local Law 144 of 2021 (Int. No. 1894-A), codified in NYC Administrative Code §§ 20-870 to 20-874, regulates the use of "automated employment decision tools" (AEDTs) by employers and employment agencies for employment decisions about New York City candidates and employees.

The Department of Consumer and Worker Protection (DCWP) finalized its rules in April 2023, with enforcement starting July 5, 2023.

What counts as an AEDT

The DCWP rules define an AEDT as a computational process that:

Is derived from machine learning, statistical modeling, data analytics, or artificial intelligence,
Issues a simplified output (a score, classification, or recommendation),
Is used to substantially assist or replace discretionary decision-making for employment decisions.

"Substantially assist or replace" is the key phrase. DCWP interprets it narrowly: the AEDT must be the sole criterion, weighted more heavily than other criteria, or used to overrule conclusions from other criteria.

Typical AEDTs in scope:

Resume screeners that score or rank candidates
Interview scoring tools (including one-way video AI scoring)
Coding-assessment auto-grading when used to filter
Predictive analytics for promotion or compensation

Typically not in scope:

Pure keyword search without scoring
Tools that only schedule interviews
Tools whose output is reviewed in detail by a human and combined with multiple other inputs of comparable weight

The three core obligations

1. Annual independent bias audit

Before using an AEDT to evaluate a NYC candidate, you must have a bias audit completed within the prior year. The audit must:

Be conducted by an independent auditor — no employment or financial relationship with the employer or vendor that impairs independence.
Calculate selection rates and impact ratios for each EEO-1 sex, race/ethnicity, and intersectional category.
Use historical data (your actual candidate data when available; test data from the vendor as a fallback, with disclosure).

2. Public posting of audit summary

On the employer's careers website (or a page linked from it) you must post:

The date of the most recent audit
Source and explanation of the data used
The selection rates and impact ratios for each category
The distribution date of the AEDT

This summary must remain on the website for at least 6 months after the AEDT is last used.

3. Candidate notice

At least 10 business days before using an AEDT on a NYC candidate, you must:

Notify the candidate that an AEDT will be used,
Disclose the job qualifications and characteristics the AEDT will assess,
Disclose the type of data collected and its source (on request, within 30 days),
Provide instructions on how to request an alternative selection process or accommodation.

Penalties

$500 for a first violation. $500 to $1,500 for each subsequent violation. Each day of non-compliance and each candidate not properly notified can constitute a separate violation. DCWP enforces.

The artifacts you need on file

If DCWP or a candidate's attorney sends a discovery request, these are the documents that decide whether you're defensible:

Independent auditor's signed bias audit report (within prior year)
Source data used in the audit + methodology disclosure
Selection rate and impact ratio tables by EEO-1 category
Public-facing audit summary posted to careers site (with timestamp)
Candidate notice template + delivery logs (date sent, recipient, method)
Per-candidate scoring trail: which AEDT scored them, what input features, what output
Vendor documentation describing how the AEDT works
Internal policy defining when AEDT output "substantially assists" decisions

Practical compliance checklist

Use this as your starting point.

Inventory every tool used in your NYC hiring process. Flag anything that scores, ranks, or classifies candidates.
For each flagged tool, determine if it meets the AEDT definition. Document your reasoning either way.
For in-scope AEDTs, commission an independent bias audit. Allow 6–10 weeks.
Post the audit summary on your careers page. Add a clear, dated heading.
Update your candidate-facing communications: add AEDT notice to job postings and application confirmations.
Build an alternative-process path for candidates who request one.
Configure your ATS or interview platform to log per-candidate AEDT input/output for audit purposes.
Calendar the next audit for 11 months out — don't let the prior-year window expire.
Train recruiters and hiring managers on what they can and can't say about the AEDT to candidates.
Document your internal policy on when AEDT output is "substantially assisting" decisions, so future audits and discovery are straightforward.

How Greenroom helps

Greenroom is built so the artifacts above are produced automatically:

Per-candidate scoring trail with the question bank, rubric, and scores for every interview round.
Selection-rate and impact-ratio reports generated on demand for any date range.
Candidate notice template with 10-day pre-use scheduling and delivery logs.
Audit-ready export pack: one click produces the documents an independent auditor or DCWP investigator asks for.
Public audit summary widget you can embed on your careers site.

Talk to our compliance team See how Greenroom works

Frequently asked questions

Does NYC LL 144 apply to remote candidates living outside NYC?

It applies to candidates for positions in NYC and current NYC-based employees being considered for promotion. Remote roles based out of a NYC office are typically in scope.

Does the law cover tools developed in-house?

Yes. The definition is functional, not vendor-based. An in-house ML model that scores resumes is just as in scope as a vendor product.

What if my vendor publishes a "platform-wide" bias audit?

That doesn't satisfy your obligation. The audit must reflect the AEDT as used by your employer, ideally on your historical data.

How does NYC LL 144 interact with the EU AI Act?

The EU AI Act classifies recruitment AI as high-risk and imposes broader transparency, documentation, risk-management, and human-oversight obligations. Compliance with one doesn't automatically satisfy the other, but the documentation overlaps substantially. See our EU AI Act guide.

Who enforces NYC LL 144?

The NYC Department of Consumer and Worker Protection (DCWP).

Not legal advice. This guide is informational. For an authoritative compliance determination, consult employment counsel familiar with NYC labor law and your specific AEDTs.