Question 1

What must be on the NYC LL144 public disclosure page?

Accepted Answer

Under NYC Admin. Code § 20-871(b), the required disclosure page must include: (1) the date of the most recent bias audit, (2) the summary of results including selection rate and impact ratio for each sex, race/ethnicity, and intersectional EEO category, (3) the name and contact information of the independent auditor, and (4) whether the bias audit was conducted on the employer's own historical data or a test dataset. Missing any of these elements is a violation.

Question 2

What is the penalty for not publishing the NYC LL144 disclosure page?

Accepted Answer

The NYC Department of Consumer and Worker Protection (DCWP) issues civil penalties of $375 per day for a first violation and $1,500 per day for subsequent violations under 6 RCNY § 5-300 et seq. Penalties accrue from the date of first use of the AI hiring tool without a required disclosure page — not from the date the DCWP issues a notice of violation. An employer who has used an AI hiring tool since 2023 without a disclosure page could owe years of accumulated daily penalties.

Question 3

Does running the NYC LL144 bias audit satisfy the disclosure requirement?

Accepted Answer

No. Running the bias audit and publishing the disclosure page are two separate requirements under NYC LL144. Employers who complete the audit but fail to publish the results on their public website are in violation of NYC Admin. Code § 20-871(b). The DCWP has cited employers who conducted valid bias audits but did not post the required disclosure page — treating it as a full, independent violation.

Question 4

Can the LL144 disclosure page be behind a login?

Accepted Answer

No. Under DCWP guidance interpreting 6 RCNY § 5-300 et seq., the disclosure page must be publicly accessible without requiring login or registration. Posting the disclosure in an employer portal, HR system, or behind an applicant account login does not satisfy the requirement. The page must be accessible to any member of the public who navigates to the employer's website.

Question 5

How often must the NYC LL144 disclosure page be updated?

Accepted Answer

The disclosure page must be updated within 30 days of completing a new bias audit. NYC LL144 requires a new bias audit at least annually if the employer continues using the covered AI hiring tool. The previous year's disclosure results alone do not satisfy the current compliance period — the page must reflect the most recent audit cycle. EmployArmor sends annual update reminders keyed to your audit completion date.

Question 6

What AI hiring tools are covered by NYC LL144?

Accepted Answer

NYC LL144 covers 'automated employment decision tools' (AEDTs) used by employers or employment agencies in NYC to substantially assist or replace discretionary decision-making in hiring or promotion decisions. This includes AI resume screening tools, AI video interview scoring platforms, AI-based assessment tools, and algorithmic candidate ranking systems. Employers with NYC-based candidates or roles must assess whether their AI hiring tools qualify as AEDTs under the law.

Question 7

What are the impact ratio requirements in the LL144 disclosure?

Accepted Answer

The bias audit must calculate and the disclosure must include the selection rate and impact ratio for each combination of sex and race/ethnicity category for which the audit collected data. The impact ratio is calculated by dividing the selection rate of the group with the lower rate by the rate of the group with the highest rate. An impact ratio below 0.8 (the 4/5ths rule from 29 C.F.R. § 1607) signals potential adverse impact and must be disclosed even if the employer continues using the tool.

Question 8

What happens during a DCWP LL144 investigation?

Accepted Answer

The DCWP investigates LL144 violations through complaint intake and spot audits. When a complaint is filed, the DCWP issues a notice of alleged violation and gives the employer an opportunity to cure. Employers have a right to respond and present evidence of compliance. If the violation is sustained, daily penalties are assessed from the date of first violation. Employers who have a disclosure page published and an audit on file are in a far stronger position to resolve complaints quickly.

Question 9

Does NYC LL144 apply to employers outside NYC who hire NYC workers?

Accepted Answer

Yes. NYC LL144 applies to employers and employment agencies that use covered AI hiring tools to evaluate candidates for positions located in NYC — regardless of where the employer's headquarters is located. A Chicago-based company that uses AI screening for its NYC office staff must comply with LL144's bias audit and disclosure requirements for those NYC positions.

Question 10

Can employers use their AI vendor's bias audit for LL144 compliance?

Accepted Answer

Only if the vendor's audit was conducted by an independent auditor meeting DCWP requirements and covers the employer's actual use of the tool. Under 6 RCNY § 5-300, the bias audit must be conducted by an independent auditor who is not employed by the employer or the AI tool vendor, and the audit must evaluate the tool's performance using the employer's own use case data when available. Vendor-conducted audits or vendor-provided test dataset audits may not satisfy the independence requirement.

NYC LL144 Disclosure Page FAQ: What Employers Must Publish

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