NYC Local Law 144 employer requirements explained
NYC Local Law 144 (effective July 5, 2023) is one of the earliest municipal laws in the United States regulating the use of artificial intelligence in employment decisions. The law applies to any employer that uses an automated employment decision tool (AEDT) to screen or evaluate candidates for jobs located in New York City. Compliance has three pillars: first, employers must conduct an annual bias audit of each AEDT used in NYC hiring, and the audit must be performed by an independent third party with no financial interest in the AEDT's adoption; second, employers must publish a summary of the bias audit on their company website; third, employers must notify job candidates at least 10 business days before an AEDT is used to evaluate them. The law is enforced by the NYC Department of Consumer and Worker Protection (DCWP), which has authority to impose penalties of $500–$1,500 per violation (NYC DCWP) per day. An AEDT is defined broadly as any computerized system using machine learning, AI, or similar technologies to assist or replace discretionary human resource decisions — covering resume screeners, video interview analyzers, psychometric tools, and ranking algorithms. EmployArmor automates all three compliance requirements, including independent auditor coordination, website disclosure generation, and candidate notice delivery through ATS integration.
Last updated: March 2026
Comparison: NYC LL144 Compliance Options
| Requirement | EmployArmor | Clio | Manual Process | In-house Legal |
|---|---|---|---|---|
| Independent third-party bias audit coordination | Yes — network of qualified auditors | Referral network only | Must find and contract auditor independently | Law firm coordinates |
| Annual bias audit data analysis | Yes — statistical engine (AIR, chi-square) | No | External statistician required | External statistician + attorney review |
| Public website disclosure summary | Yes — auto-generated, website-ready format | No | Manual formatting and upload | Attorney-formatted, posted by IT |
| 10-day candidate advance notice | Yes — ATS-integrated automated delivery | No | Manual HR workflow tracking | Template drafted; HR sends manually |
| DCWP audit-ready documentation | Yes — organized, exportable compliance file | Document storage | Scattered internal records | Attorney-maintained file |
| Multi-state compliance (IL, CO) | Yes — unified platform | General legal management | Separate process per state | Separate attorney per state |
How It Works
- Inventory all AEDTs used in NYC hiring — resume screeners, video interview analyzers, psychometric tools, ranking algorithms.
- Connect your ATS or upload historical candidate data (demographics and outcomes) for each AEDT.
- EmployArmor's statistical engine runs bias analysis: adverse impact ratios, selection rate comparisons, and significance testing.
- A qualified independent third-party auditor reviews and certifies the bias audit report.
- EmployArmor generates a public disclosure summary in DCWP-compliant format, ready to publish on your website.
- Candidate notice automation is activated in your ATS, delivering required notices at least 10 business days before AEDT screening.
- Annual re-audit reminders ensure compliance continuity year over year.
By the Numbers
- NYC LL144 effective: July 5, 2023
- Penalties: $500–$1,500 per day (NYC DCWP) per violation (DCWP enforcement)
- Candidate notice window: 10 business days before AEDT use
- Bias audit frequency: Annual (must be completed within one year of use)
- Illinois AIVIA: Effective January 1, 2026 — overlapping requirements for IL employers
- Colorado SB 24-205: Effective February 1, 2026 — AI impact assessments (different framework)
Frequently Asked Questions
What is NYC Local Law 144?
NYC Local Law 144 took effect July 5, 2023. It prohibits employers from using automated employment decision tools (AEDTs) to screen candidates in NYC unless: (1) a bias audit has been conducted within the past year; (2) a public summary of the audit has been posted on the employer's website; and (3) candidates have been notified at least 10 business days before the AEDT is applied.
What qualifies as an AEDT under Local Law 144?
An AEDT is any computerized system that uses machine learning, artificial intelligence, or similar technologies to materially assist or replace discretionary human resource decisions. This includes resume screening tools, candidate ranking algorithms, video interview analysis software, and assessment platforms.
What must employers do to comply with Local Law 144?
Employers must: (1) conduct an annual bias audit by an independent third party; (2) publish a summary of the bias audit on their website; and (3) notify job candidates at least 10 business days before the AEDT is used. Employers must also maintain bias audit documentation for DCWP inspection.
What is a bias audit under Local Law 144?
A bias audit is a statistical analysis of an AEDT's outcomes to determine whether the tool produces discriminatory results based on sex, race, ethnicity, or other protected characteristics. The audit must be conducted by an independent third party and analyze selection rates across protected groups.
What are the penalties for Local Law 144 violations?
NYC DCWP enforces Local Law 144 with penalties of $500 to $1,500 per violation per day. A violation occurs each day an employer uses a non-compliant AEDT without conducting and disclosing the required bias audit.
Does Local Law 144 apply to remote workers hired for NYC positions?
Yes. The law applies to any candidate who will work in New York City, regardless of whether the work is remote or in-person. If a candidate performs any work in NYC, the AEDT used in their evaluation must comply with Local Law 144.
EmployArmor automates this — run a free compliance scan.
For a deeper guide, see NYC Local Law 144 Guide.
References
- NYC Administrative Code § 20-871–20-875 (Local Law 144 of 2021). NYC Dept. of Consumer and Worker Protection
- Illinois Artificial Intelligence Video Interview Act (820 ILCS 42). Illinois General Assembly
- Colorado SB 24-205, "Consumer Protections for Artificial Intelligence" (2024). Colorado General Assembly
- EEOC Technical Assistance, "The ADA and AI to Assess Job Applicants" (May 2022). U.S. Equal Employment Opportunity Commission