Question 1

Does NYC Local Law 144 require public posting of bias audit results?

Accepted Answer

Yes. NYC Local Law 144 requires employers to make a summary of the most recent bias audit publicly available on their website before using an automated employment decision tool on candidates in NYC. The public posting must include: the date of the most recent bias audit, the name of the independent auditor who conducted it, and the summary statistics showing the selection rate for each race, sex, and intersectional category. The audit itself can be internal, but the summary must be publicly accessible.

Question 2

What happens if an employer has a bias audit but no public posting?

Accepted Answer

An employer who conducts a bias audit but does not post the required public summary is still in violation of NYC Local Law 144. The public disclosure requirement is a separate obligation from the audit itself. NYC's Department of Consumer and Worker Protection has indicated in enforcement guidance that it will treat a missing public disclosure as a standalone violation, regardless of whether an audit was completed. Penalties start at $375 per day for the first violation.

Question 3

Where exactly must the public bias audit summary be posted under NYC LL144?

Accepted Answer

Under NYC Local Law 144, the bias audit summary must be posted on the employer's public-facing website. The page must be publicly accessible without a login or registration. It cannot be posted only in an applicant portal or behind any authentication wall. Many employers add a dedicated page (often titled 'AI Hiring Tool Disclosures' or similar) and link to it from their careers or legal pages.

Question 4

How often must the public AI hiring disclosure be updated?

Accepted Answer

Under NYC Local Law 144, the bias audit must be conducted annually and the public summary must be updated to reflect the most recent audit. If you conduct a new audit, you must update the public posting before using the refreshed AI tool on candidates. A disclosure based on an audit that is more than 12 months old is treated as a stale disclosure and does not satisfy the current requirement.

Question 5

What are the penalties for missing the public AI hiring disclosure under NYC LL144?

Accepted Answer

NYC Local Law 144 penalties start at $375 per day for the first violation. Subsequent violations carry penalties up to $1,500 per day. Each day the AI tool is used on candidates without a compliant public disclosure is a separate daily violation. Enforcement is handled by NYC's Department of Consumer and Worker Protection (DCWP). Complaints can be filed by candidates, employees, or advocacy organizations.

Question 6

Does Colorado require public disclosure of AI hiring tool assessments?

Accepted Answer

Colorado's SB24-205, effective February 2026, requires employers using high-risk AI systems to conduct impact assessments and make certain disclosures. The law includes requirements to notify individuals when AI is used in consequential decisions and to make information about AI use available upon request. Colorado's disclosure requirements are evolving and differ from NYC's public posting requirement — but employers operating in Colorado should document their AI use and be prepared to provide impact assessment summaries.

Question 7

What do Illinois AI hiring disclosure requirements require?

Accepted Answer

Illinois AIVIA, effective January 2026, requires employers to notify candidates when AI video analysis is used to evaluate them. Illinois does not yet require public posting of bias audit summaries in the same way NYC does, but employers must provide individual candidate notices about AI use. Illinois is monitoring federal and NYC enforcement patterns and may expand disclosure requirements in future legislative sessions.

Question 8

Can a candidate request a copy of the bias audit results?

Accepted Answer

Under NYC Local Law 144, candidates can request a copy of the publicly posted bias audit summary. The public posting itself is the mechanism for satisfying this right — the summary must be on the employer's website so any candidate can access it without making a formal request. Employers are not required to provide the full underlying audit data, only the required summary statistics.

Question 9

Does the public disclosure requirement apply to AI tools used by staffing agencies?

Accepted Answer

Yes. NYC Local Law 144 applies to employers and employment agencies that use automated employment decision tools on candidates for jobs in NYC. Staffing agencies using AI screening tools on behalf of client employers must ensure compliant bias audits and public disclosures are in place. The employer (client company) and the agency can share disclosure responsibilities, but the disclosure must be publicly accessible before the tool is used.

Question 10

How does the public disclosure requirement interact with the bias audit requirement?

Accepted Answer

They are sequential requirements: first you conduct the bias audit with an independent auditor, then you post the required summary publicly, then you may use the AI tool on candidates. Skipping the public posting step — even after a valid audit — means you are using the tool without satisfying all of LL144's requirements. EmployArmor handles both steps: the bias audit coordination and the subsequent public disclosure posting and verification.

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