Complying with NYC Local Law 144
What Employers Need to Do
New York City’s Local Law 144 of 2021 regulates the use of Automated Employment Decision Tools (AEDTs)—software that scores, ranks, classifies or recommends candidates or employees in a way that “substantially assists or replaces” human decision-making in hiring or promotion. If you use résumé screeners, assessment algorithms, ranking engines, or similar tools for New York City roles or NYC-based candidates, this law applies to you.
What the law requires (in plain English)
Annual, independent bias audit before use
You may not use (or continue to use) an AEDT unless it has undergone an independent bias audit within the past year and you have posted a public summary of the audit and the tool’s distribution date on your website.
Advance notice to candidates/employees
For any NYC candidate (or NYC employee considered for promotion), you must give at least 10 business days’ notice that an AEDT will be used, list the job qualifications/characteristics the tool evaluates, and provide data/retention information on request. Candidates must be allowed to request an alternative selection process or accommodation.
Post what the audit must include
The public audit summary needs to show key metrics (e.g., selection/scoring rates and impact ratios by sex and race/ethnicity categories, plus the AEDT version/distribution date and data sources).
Enforcement began July 5, 2023 and is handled by NYC’s Department of Consumer and Worker Protection (DCWP). Discrimination claims involving AEDTs are referred to the NYC Commission on Human Rights.
What counts as an AEDT?
Any computational process (ML/AI/statistical modeling/data analytics) that outputs a score, classification, ranking or recommendation and is used to substantially assist or replace human discretion in hiring or promotion decisions. (This does not include generic tools like spam filters, firewalls, calculators, or plain databases/spreadsheets.)
Fines & how they stack up
NYC can assess $500 for a first violation (and other violations on the same day) and $500–$1,500 for each subsequent violation.
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Per-day violations: Each day an AEDT is used without a timely audit/posting is a separate violation
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Per-candidate violations: Each failure to give required notice to a candidate/employee is a separate violation.
There is no stated cap on total penalties.
Concrete scenarios (for illustration)
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Scenario A — No notice for 100 applicants (NYC-covered):
Each missed notice is a separate violation. Minimum exposure: 100 × $500 = $50,000. Maximum exposure (counting the first at $500 and 99 at $1,500): $149,500.
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Scenario B — No bias audit / no posting for 7 days:
Daily violation for using the tool in violation. Range: Day 1 up to $500, Days 2–7 up to $1,500/day → $9,500 max (or $3,500 at the low end).
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Scenario C — Both A + B (stacking):
Missed notices for 100 applicants ($149,500 max) plus 7 days of non-audited use ($9,500 max) → ~$159,000 in potential penalties.
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Scenario D — Limited use (20 applicants; 3 days non-audited):
Notice failures: 20 × up to $1,500 = $30,000 max.
Daily audit/posting failures: Day 1 up to $500 + Days 2–3 up to $1,500/day = $3,500 max.
Total max ≈ $33,500.
These are illustrative ranges based on the statute’s penalty structure. Actual outcomes depend on facts, agency discretion, and any defenses/mitigations you present. This is not legal advice.
How BiasSignal helps you comply (fast)
LL144-ready Bias Audits
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Independent audit aligned to DCWP rules, with impact-ratio and selection/scoring-rate analysis across required groups (and intersections where feasible). You get a public-posting summary that meets content expectations. (Workforce Bulletin)
Notice automation
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Generate legally required 10-business-day notices for job pages, careers portals, and candidate communications—plus built-in language to offer alternative processes/accommodations. (NYC Council)
Audit-summary page & versioning
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A hosted, public audit-summary page with the AEDT distribution date, audit date, data sources, and methodology—kept in sync when your tool or data changes. (NYC Council)
Evidence & record-keeping
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Centralized audit files, notice logs, AEDT versions, and change records to demonstrate good-faith compliance in the event of a DCWP inquiry.
Risk-reduction playbook
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Practical remediation guidance (feature reviews, data quality checks, thresholds, human-in-the-loop controls) to improve outcomes while staying consistent with broader anti-discrimination obligations. (Gibson Dunn)
Quick FAQ
Does sending a general “careers site” notice work?
DCWP materials indicate employers can provide website notice and begin using an AEDT 10 business days after posting (position-specific notice is not always required, but you must still describe qualifications/characteristics the tool uses).
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Who is covered?
The law applies when you screen candidates for NYC jobs or assess NYC employees for promotion using an AEDT; the candidate/employee resides in NYC for notice purposes.
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What if the audit shows disparities?
LL144 requires the audit/posting/notice steps; any discrimination claims are handled under the NYC Human Rights Law by the Commission on Human Rights, not DCWP. You still must comply with all anti-discrimination laws.
Get compliant (and stay that way)
BiasSignal gives you a turn-key LL144 package: independent audit, ready-to-post summary, notice automation, and compliance evidence—all designed to reduce risk and keep your hiring moving.
Book a 30-minute consult to scope your AEDTs and timeline.
Request a sample audit summary to see exactly what you’d post. (Just click on the "Contact" button at the top of the page)
Disclaimer: This page is for general information only and is not legal advice. Consult counsel about your specific situation.