Question 1

What is an AI bias audit under NYC Local Law 144?

Accepted Answer

An AI bias audit under NYC Local Law 144 is an independent statistical analysis of an automated employment decision tool (AEDT) to determine whether it creates disparate impact across race, sex, or intersectional categories. The audit must be conducted by an independent auditor with no prior financial or employment relationship with the employer or AEDT vendor. Results must be published on the employer's website before the tool is used.

Question 2

Who is required to conduct a bias audit?

Accepted Answer

Any employer or employment agency that uses an automated employment decision tool (AEDT) to screen job candidates or employees in New York City must commission an annual bias audit. The auditor must be independent — meaning no employment or financial relationship with the employer or the AEDT vendor for at least the prior two years. Internal HR teams and the AEDT vendor's own analysts cannot conduct the required audit.

Question 3

What must a NYC LL144 bias audit include?

Accepted Answer

A compliant bias audit must calculate the selection rate for each demographic category and the impact ratio comparing each group's rate to the highest-scoring group. Categories include sex, race and ethnicity, and intersectional combinations. If the AEDT scores rather than selects, the audit must analyze score distributions. The audit summary, auditor name, and date must all be posted on the employer's website.

Question 4

What are the penalties for not completing an annual bias audit?

Accepted Answer

Under NYC Local Law 144, employers who use an AEDT without a compliant bias audit face civil penalties of $375 for a first violation and up to $1,500 per day for subsequent violations. Each day of non-compliance is a separate violation. Employers must also notify candidates at least 10 business days before using the AEDT, or face additional per-violation penalties.

Question 5

How often must a bias audit be completed?

Accepted Answer

NYC Local Law 144 requires a bias audit at least once per year for any AEDT in active use. If a new version of the tool is deployed or the tool is materially updated, a new audit may be required before the updated version is used. Employers should establish an annual audit calendar and build the auditor engagement process into their compliance workflow.

Question 6

Does the bias audit need to be made public?

Accepted Answer

Yes. The summary of bias audit results must be posted on the employer's public website in a clear and accessible location. The posting must include the date of the audit, the name of the independent auditor, the AEDT name and version, and the impact ratios by demographic group. The posting must remain available as long as the employer uses the AEDT.

Question 7

What states require bias audits beyond NYC?

Accepted Answer

As of 2026, NYC Local Law 144 is the most specific bias audit mandate. Illinois AIVIA requires employers to conduct a bias review before using AI for video interviews. Colorado SB24-205, effective June 2026, requires impact assessments for high-risk AI systems used in hiring. California has multiple bills pending that would add bias audit requirements. Maryland and other states are in early legislative stages.

Question 8

How much does a bias audit cost?

Accepted Answer

Independent bias audits typically cost between $5,000 and $30,000 depending on the complexity of the AEDT, the number of demographic categories analyzed, and the auditor's firm. Costs vary based on data availability from the vendor and how much statistical work must be done from scratch. EmployArmor helps employers prepare their data and coordinate with auditors, reducing the time and cost of the engagement.

Question 9

What is an automated employment decision tool (AEDT) under LL144?

Accepted Answer

Under NYC Local Law 144, an AEDT is any computational process derived from machine learning, statistical modeling, data analytics, or AI that issues simplified output such as a score, classification, or recommendation that is used to substantially assist or replace discretionary decision-making in the hiring or promotion process. This includes resume screeners, video interview analysis tools, and candidate scoring platforms from vendors like HireVue, Pymetrics, and similar products.

Question 10

How does EmployArmor help with bias audit compliance?

Accepted Answer

EmployArmor's bias audit tool manages the entire compliance workflow: it tracks your audit schedule, coordinates with independent auditors, prepares your AEDT data for analysis, generates the required public disclosure document, and archives all audit records for regulatory review. It also monitors upcoming changes in Illinois, Colorado, and other states so you are never caught off guard by new requirements.

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