In effect — audits due annually

NYC Local Law 144 — AI Hiring Bias Audit Requirements

Q: Does Local Law 144 apply if we're a company outside New York City?

Yes. The law applies based on where the employment decision affects workers, not where the employer is located. If you use an AEDT to screen candidates for positions where their primary worksite would be in New York City — including remote positions — you are covered.

Q: What vendors qualify as an independent auditor for the bias audit?

The auditor must not be the employer or the AEDT vendor and must have no financial interest in the tool's continued use. NYC DCWP has published guidance on auditor independence standards. In practice, you should engage a third-party statistical auditing firm or consulting practice with documented independence from your AEDT vendor.

Q: What does the bias audit actually measure?

Audits must calculate the selection rate (the rate at which the tool selects candidates to advance) broken down by sex (male, female, non-binary where data exists) and by race/ethnicity categories. The impact ratio compares selection rates across groups. Results showing statistically significant disparities require disclosure regardless of the explanation.

Q: Do we need a new audit every year?

Yes. The law requires a bias audit conducted no more than one year before the AEDT is used. There is no exception for using the same tool year over year — a fresh audit from a qualifying independent auditor is required annually to remain compliant.

NYC Local Law 144 is in effect. Any employer using automated employment decision tools for NYC-based roles — including remote positions with NYC applicants — must conduct annual independent bias audits and post results publicly. The daily penalty for violations starts at $500.

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NYC Local Law 144: AI hiring audit requirements

What Local Law 144 requires

NYC Local Law 144 (effective July 5, 2023) prohibits employers from using an Automated Employment Decision Tool (AEDT) to screen candidates or employees for jobs in New York City unless they have commissioned an independent bias audit in the prior year and published a summary of its results. The law applies to any employer using an AEDT to meaningfully assist in employment decisions affecting NYC workers.

Who must comply — including remote employers

Coverage is not limited to employers physically located in New York City. Any employer that uses an AEDT to make hiring or promotion decisions affecting individuals whose primary worksite would be in New York City is covered. This includes remote employers who recruit for NYC-based remote or hybrid positions. Small businesses are not expressly exempt.

Independent bias audit standards

Audits must be conducted by an independent auditor — not the tool's vendor. The audit must calculate selection rates disaggregated by sex, race/ethnicity, and intersectional categories. Results must be posted publicly on the employer's website for at least six months and include the date of the audit, the auditor's name, and the results summary.

Candidate notice obligations

Before using an AEDT in a hiring or promotion process, employers must notify candidates or employees at least 10 business days in advance that an AEDT will be used. Notice must include what job qualification the tool evaluates and what characteristics it uses. Candidates must be offered an alternative selection process or accommodation upon request.

Frequently asked questions

Does Local Law 144 apply if we're a company outside New York City?

What vendors qualify as an independent auditor for the bias audit?

What does the bias audit actually measure?

Do we need a new audit every year?

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