$375/day for missing disclosure — even if you ran the audit

NYC LL144 Disclosure Page Generator

NYC Local Law 144 (NYC Admin. Code § 20-871(b)) requires employers to post bias audit results publicly on their website before using AI hiring tools. The DCWP cites employers who ran the audit but never published.

EmployArmor generates your required NYC LL144 disclosure page in DCWP-compliant format and publishes it to your career site automatically — so the audit you paid for actually counts.

Required
Must post before first use
$375/day
First violation penalty per day
Yes
Annual update required
Public
Must be on company website

NYC LL144 Disclosure Page Requirements

The DCWP has issued detailed rules under 6 RCNY § 5-300 et seq. specifying exactly what must be on the disclosure page, where it must appear, and when it must be updated.

What Must Be Disclosed

Under NYC Admin. Code § 20-871(b), disclosure must include: bias audit date, auditor name, selection rates and impact ratios by EEO category, and whether the audit used the employer's own data or a test dataset. Missing any required element is a violation.

Where to Post It

The disclosure must be on the employer's public website — on the careers page or a dedicated compliance page. The DCWP rules under 6 RCNY § 5-300 et seq. require accessibility without login. Internal portals do not satisfy this requirement.

When to Update

After each annual bias audit, the disclosure page must be updated within 30 days of the new audit's completion date. Using the prior year's disclosure for a new audit cycle is a violation — even if the results are similar.

Format Requirements

The DCWP has issued specific format guidance under 6 RCNY § 5-300 et seq. The disclosure must identify the covered tool by name, include impact ratios in a readable format, and include the audit date prominently. Auto-generated PDFs buried in footnotes do not satisfy the requirement.

What EmployArmor Does

Auto-generate and publish your LL144 disclosure page

The bias audit is only half the requirement. EmployArmor takes your audit results and generates the required public disclosure page in DCWP-specified format — then publishes it directly to your career site.

  • Disclosure page generator in DCWP-required format
  • Auto-publish to your career site with one click
  • Annual update reminders keyed to your audit cycle
  • DCWP format compliance check before publishing
  • Multi-tool disclosure management for employers with multiple AI hiring tools
  • Version history for every disclosure update
Disclosure Requirements by Jurisdiction

AI Hiring Disclosure Requirements by State

NYC LL144 is the strictest public disclosure requirement, but Illinois AIVIA and Colorado SB24-205 have their own disclosure obligations.

JurisdictionStatusRisk
New York CityIn effect — enforcement activeHigh
New York StateStatewide bill under reviewMedium
IllinoisIn effect — disclosure requiredHigh
ColoradoIn effect — impact assessment + disclosureMedium

Updated March 2026. EmployArmor monitors all 50 states for AI hiring disclosure requirements.

The Most Commonly Missed NYC LL144 Requirement

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The NYC CCHR's LL144 guidance makes clear that the disclosure page requirement is independent of the bias audit requirement. Employers who paid for an audit but didn't publish the results are just as exposed as those who never ran the audit at all.

The DCWP enforces through complaint review and spot audits of employer career sites. Violators receive a notice of violation and have the right to cure — but penalties accrue from the date of first use, not from the notice date. An employer using an AI hiring tool since 2023 without a disclosure page could owe months of accumulated daily fines.

EmployArmor's AI Bias Audit Tool and disclosure page generator work together — once your audit is complete, the disclosure page is generated and published automatically. See the full NYC Local Law 144 compliance guide or our AI hiring compliance checklist.

Regulatory references: NYC CCHR LL144 guidance, NYC Admin. Code § 20-871(b), 6 RCNY § 5-300 et seq.

Frequently Asked Questions

What does NYC Local Law 144 require employers to publish?

Under NYC Admin. Code § 20-871(b), employers using AI hiring tools in NYC must publish the results of their bias audit on their website before using the tool. The disclosure must include: the date of the most recent bias audit, the summary of results (including selection rate and impact ratio for each EEO category), the name of the independent auditor, and whether the audit covered the employer's actual use or a historical dataset. The page must be publicly accessible — not behind a login.

What are the penalties for not publishing the NYC LL144 disclosure page?

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. The DCWP has made clear that failing to publish the disclosure page is an independent violation — separate from failing to conduct the bias audit. Employers who completed a bias audit but failed to post it publicly have been cited.

Where must the LL144 disclosure page be posted?

Under NYC Admin. Code § 20-871(b), the disclosure must be published on the employer's website — either on a dedicated page or on the careers/jobs page where applicants would reasonably look. The DCWP rules (6 RCNY § 5-300) clarify that the page must be accessible without login or registration. Posting only in an employee portal or behind an applicant login does not satisfy the requirement.

How often must the NYC LL144 disclosure page be updated?

The disclosure must be updated within 30 days of completing a new bias audit. NYC LL144 requires a new independent bias audit at least once every year if the employer continues using the covered AI hiring tool. When a new audit is completed, the disclosure page must reflect the new results within 30 days — the prior year's results alone are insufficient to maintain compliance for a new audit cycle.

What is the most common NYC LL144 compliance mistake employers make?

The most common mistake is completing the bias audit but not publishing the required disclosure page. Many employers assume that having the audit report on file satisfies the law — it does not. The DCWP specifically requires public posting on the company's website. EmployArmor's disclosure page generator automatically formats the audit results in DCWP-compliant format and publishes it to the employer's career site.

More questions? See our full NYC LL144 disclosure page FAQ.

Generate and Publish Your LL144 Disclosure Page Today

Your bias audit only counts if you publish the results. EmployArmor formats and publishes your required NYC LL144 disclosure page automatically.