AI Bias Audit
Tool
NYC Local Law 144 requires an annual independent bias audit for every AI hiring tool — with results posted publicly. Illinois AIVIA and Colorado SB24-205 are next.
EmployArmor coordinates your independent auditor, runs the required statistical analysis across all demographic groups, generates the public disclosure document, and archives every audit for regulatory review.
What a Bias Audit Requires
This is not an internal HR review — it is a legal compliance requirement with public disclosure obligations. Here is what NYC LL144 mandates.
What a Bias Audit Must Cover
The audit must include statistical analysis of selection rates across race, sex, and intersectional categories. It must calculate adverse impact ratios and compare outcomes across all demographic groups defined by the law.
Who Can Conduct It
NYC LL144 requires an independent auditor — someone with no employment or financial relationship with the employer or AEDT vendor for at least the prior 2 years. Internal HR teams cannot conduct the required audit.
What Gets Published
Results must be posted on the employer's website before the AEDT is used. Published data must include the date of the audit, the independent auditor's name, and the bias audit summary with impact ratios by demographic group.
How Often
Audits are required at least annually — meaning every 12 months the AEDT is used for covered employment decisions. If a new AEDT version is deployed, a new audit may be required before that version is used.
LL144 Penalty Exposure Calculator
Estimate your maximum penalty exposure for NYC Local Law 144 non-compliance.
Estimates based on NYC Admin. Code § 20-875. Actual penalties determined by DCWP.
Bias audits are complex. We make them manageable.
From finding a qualified independent auditor to generating the public disclosure document, EmployArmor handles every step of the annual bias audit process — so your HR team does not have to become statisticians.
- Automated statistical analysis across 8 demographic groups
- Auditor coordination workflow — manage independent auditor engagement
- Public disclosure generator with compliant formatting
- Adverse impact tracking with historical trend charts
- Historical audit archive — every past audit at your fingertips
- Connects to your ATS and AEDT vendor automatically
Bias Audit Requirements by State
NYC started it. Illinois and Colorado are building on it. EmployArmor tracks every jurisdiction so you always know where you stand.
| State | Status | Risk |
|---|---|---|
| New York City | In effect July 2023. Annual audit + public posting required. | High |
| Illinois | In effect January 2026. Bias review required before AI video interview use. | High |
| Colorado | Effective June 30, 2026. Impact assessment includes bias review. | Medium |
| California | Multiple bills in progress targeting algorithmic bias in hiring. | Medium |
| Maryland | Early-stage legislation tracking AI hiring tool usage. | Low |
Updated March 2026. EmployArmor monitors all 50 states for AI employment legislation.
This Is Not Your HR Audit
View AI hiring lawsuits tracker →Many companies already run internal diversity reviews or HR audits on their hiring process. Those are valuable — but they do not satisfy the legal requirements of NYC Local Law 144 (NYC Admin. Code § 20-871).
LL144 requires an independent auditor — someone with no prior employment or financial relationship with your company or your AI vendor. It requires a specific statistical methodology, and the results must be published publicly before the tool is used. This is closer to a financial audit than an internal review. The NYC Commission on Human Rights enforces LL144 alongside the DCWP. The EEOC enforces Title VII (42 U.S.C. § 2000e) against AI tools that produce disparate impact nationally.
Illinois AIVIA (820 ILCS 42) requires bias review before AI video interviews are conducted, enforced by the Illinois Attorney General. Colorado's SB24-205 adds bias review as part of its pre-deployment impact assessment. The DOL OFCCP additionally monitors AI bias in hiring by federal contractors. Use our AI hiring laws by state guide to understand what applies to you.
Need an overview of everything you need to track? See our AI hiring compliance checklist.
Frequently Asked Questions: Bias Audit Requirements
What is an AI bias audit and is it legally required?
A bias audit is an independent statistical analysis of your AI hiring tool's selection rates across race, sex, and intersectional categories. NYC Admin. Code § 20-871 (Local Law 144) makes it legally mandatory — you must complete one annually and post the results publicly before using any AEDT on NYC candidates. Illinois 820 ILCS 42 (AIVIA) requires a similar review before AI video interview tools are used.
Who qualifies as an independent auditor?
NYC LL144 requires someone with no employment or financial relationship with your company or your AI vendor for at least the prior 2 years. Internal HR staff, your AI vendor, and any consultant with a financial stake in your hiring process do not qualify. The auditor's name must be included in the published summary.
What happens if I skip or delay a bias audit?
NYC penalties start at $375/day for a first violation and escalate to $1,500/day. Beyond city fines, the EEOC (42 U.S.C. § 2000e) can pursue a Title VII disparate impact claim if your AI tool disproportionately screens out protected classes — even without any intent to discriminate.
How often must a bias audit be conducted?
At minimum, annually — within 12 months of the prior audit. If you deploy a materially updated AI tool, a new audit may be required before that version is used on candidates. Colorado SB24-205 adds its own pre-deployment review requirement in addition to NYC's annual cycle.
Does the bias audit have to be made public?
Yes. Under NYC Admin. Code § 20-871, the audit summary — including the audit date, auditor name, and selection rates by demographic group — must be posted publicly on your website before the AI tool is used on candidates in NYC. Keeping it internal does not satisfy the law.
Complete NYC LL144 Compliance in 3 Steps
LL144 has three requirements. EmployArmor has a tool for each one.
Get Your Bias Audit in Order
Every day without a compliant bias audit is another day of potential $1,500 penalties. Start your compliance assessment now.