Public AI Hiring
Disclosures
NYC Local Law 144 requires employers to publicly post their bias audit results before using AI hiring tools on candidates. Most employers who conduct a bias audit forget the public posting requirement entirely.
EmployArmor formats your bias audit results into a compliant public disclosure, posts it to your website, and sends annual update reminders — so you're never using a tool without the required public summary in place.
What Public Disclosure Laws Require
NYC LL144, Colorado SB24-205, and Illinois AIVIA all include public disclosure requirements — here is what each demands and why the public posting step is so commonly missed.
What Must Be Publicly Disclosed
NYC LL144 requires employers to publish a bias audit summary including: the date of the most recent bias audit, the name of the independent auditor, and the summary statistics showing selection rates across demographic groups. The summary must be a public document — not internal.
Where It Must Be Posted
The bias audit summary must be posted on the employer's public website — not behind a login, not in an applicant portal, but on a publicly accessible page before the AI tool is used on candidates in NYC.
When It Must Be Updated
The public disclosure must be updated annually — within 12 months of the prior bias audit. If you conduct a new audit, the updated summary must be published before the refreshed AI tool is used on candidates. Stale disclosures are treated as no disclosure.
What Happens If It's Missing
NYC employers using AI hiring tools without a published bias audit summary face fines starting at $375 per day per violation. After the first violation, penalties increase to $1,500 per day. Enforcement has begun — DCWP has issued compliance guidance and is actively monitoring.
From audit results to published disclosure — automatically
Most compliance teams complete a bias audit and consider themselves done. EmployArmor takes the next step — formatting the required summary, posting it publicly, and verifying it's live — before you use the tool on a single NYC candidate.
- Bias audit summary formatter — outputs compliant disclosure text
- Automatic website posting via CMS integration or hosted page
- Annual update reminders tied to your audit schedule
- Compliance verification checker — confirms disclosure is live and accessible
- Multi-jurisdiction disclosure manager for NYC, CO, IL
- Audit trail showing when disclosures were posted and updated
Where Public Disclosures Are Required
NYC is the current enforcement leader — but Colorado and Illinois have disclosure requirements too, and California is developing them.
| Jurisdiction | Requirement | Risk |
|---|---|---|
| New York City | Public bias audit summary required on website | High |
| Colorado | Public disclosure of AI impact assessment required | Medium |
| Illinois | Employer notice requirements; public posting evolving | Medium |
| California | Public disclosure requirements under development | Medium |
Updated March 2026. EmployArmor monitors all AI disclosure requirements across jurisdictions.
Why Employers Miss the Public AI Hiring Disclosures Requirement
View AI hiring lawsuits tracker →The bias audit gets all the attention under NYC Local Law 144 (NYC Admin. Code § 20-871(b)) — and for good reason. But the law includes a second requirement that many employers overlook: the audit summary must be publicly posted on the employer's website before the AI tool is used on candidates. The NYC Commission on Human Rights has published detailed enforcement guidance on this requirement.
Employers who complete the audit but don't post the summary are non-compliant. This is one of the most common LL144 AI hiring disclosures gaps DCWP enforcement staff have flagged. Colorado Colo. Rev. Stat. § 6-1-1703(2) similarly requires public-facing disclosure about AI use in hiring decisions, enforced by the Colorado AG. The EEOC also recommends public transparency about AI selection procedures in its 2023 guidance.
EmployArmor's Public AI Hiring Disclosures tool closes this gap — formatting the audit results into the required public summary, posting it to your website, and setting annual update reminders so the disclosure never goes stale. Combined with your full AI hiring compliance checklist, it ensures you satisfy both the audit and the AI hiring disclosures requirement. See the full AI hiring laws by state for jurisdiction-specific posting requirements.
Frequently Asked Questions: AI Hiring Disclosures
What are AI hiring disclosures and who must make them?
AI hiring disclosures are public or candidate-facing notices about how AI tools influence employment decisions. NYC Admin. Code § 20-871(b) requires employers using AEDTs in NYC to publicly post their bias audit summary before using the tool. Colo. Rev. Stat. § 6-1-1703(2) requires notice to candidates about high-risk AI use under SB24-205.
Where must AI hiring disclosures be posted?
Under NYC Admin. Code § 20-871(b), bias audit summaries must be on the employer's public website — not behind a login or in an internal portal. The page must be publicly accessible before the AI tool is used on any NYC candidate. Internal records alone do not satisfy the public posting requirement.
What must the public bias audit summary include?
NYC LL144 requires: the date of the most recent bias audit, the name of the independent auditor, and summary statistics showing selection rates across demographic groups. It must be specific to the AI tool being used — a generic AI disclosure does not satisfy the requirement.
How often must AI hiring disclosures be updated?
Within 12 months of the prior bias audit. Using a stale disclosure (over 12 months old) is treated as non-compliance under NYC Admin. Code § 20-871(b). If you conduct a new audit, the updated summary must be published before the refreshed AI tool is used on candidates.
What is the penalty for missing the public posting?
NYC penalties start at $375/day for a first violation and escalate to $1,500/day. DCWP has identified the public posting requirement as one of the most commonly missed compliance obligations. Completing the bias audit without posting the summary is still a violation.
Post Your Bias Audit Summary — Before You Use the Tool
The bias audit alone isn't enough. EmployArmor handles the public posting requirement automatically.