NYC Local Law 144
AEDT Bias Audit Guide
NYC requires bias audits for AI hiring tools — and enforcement is already happening. Here's what you need to do to comply.
What is NYC Local Law 144?
NYC Local Law 144, enforced by the NYC Department of Consumer and Worker Protection (DCWP), regulates the use of automated employment decision tools (AEDTs) in hiring and promotion decisions. It was the first US municipal law to require independent bias audits for AI-powered hiring tools.
The law requires annual independent bias audits, candidate notification at least 10 business days before AEDT use, and public disclosure of audit results. Enforcement began on July 5, 2023, and the DCWP has been actively issuing violations.
Key Facts
- Enforcement: NYC Department of Consumer and Worker Protection (DCWP)
- Effective date: July 5, 2023 (active enforcement)
- Scope: AEDTs used for NYC-based positions
- Penalties: $500 first violation, $1,500 subsequent, per day
- Bias audit: Annual, independent third-party
- Candidate notice: 10 business days before use
- Cure period: None
Does NYC LL144 apply to you?
The law applies if you use an AEDT to substantially assist in hiring or promotion decisions for NYC-based positions.
Employer or Employment Agency
NYC-Based Positions
What is an AEDT?
An Automated Employment Decision Tool is any computational process derived from machine learning, artificial intelligence, or other statistical modeling that generates a simplified output (score, classification, or recommendation) used to substantially assist in hiring or promotion decisions. "Substantially assist" means the tool is a principal factor in the decision — not merely a minor input.
Exclusions: The law does not apply to tools that do not use machine learning, AI, or statistical modeling (e.g., keyword search filters that simply match terms). It also does not apply to tools used solely for internal employee management without hiring or promotion impact.
Bias Audit Requirements
An independent bias audit must be conducted annually by an impartial third-party auditor. The audit must assess the tool's impact on protected categories.
Independent Auditor
The audit must be conducted by an impartial third-party auditor who was not involved in the development of the AEDT. The auditor cannot be employed by the employer or the AEDT vendor.
Protected Categories
The audit must assess the tool's impact on sex and race/ethnicity categories. The auditor must calculate selection rates and impact ratios for each category.
Selection Rate
The proportion of individuals in a category who are selected, recommended, or classified by the AEDT. Must be calculated for each protected category.
Impact Ratio
The selection rate for a category divided by the selection rate for the most selected category. An impact ratio below 0.8 (the four-fifths rule) may indicate adverse impact.
Distribution Information
The audit must include information about the tool's distribution — the number of individuals assessed, categorized, or selected by the tool.
Public Disclosure
Audit results must be publicly available on the employer's website. The summary must include the date of the audit, the auditor's name, and the results for each category.
Candidate Notification Requirements
Candidates must be notified at least 10 business days before the AEDT is used. Notification must include specific information.
10 Business Days Before Use
The notification must include:
- That an AEDT will be used to evaluate the candidate
- The job categories for which the AEDT will be used
- Instructions for requesting an alternative selection process or reasonable accommodation
Notification Methods (any one):
- On the employer's website (career page or job posting)
- In the job posting itself
- By US mail (if the candidate has provided an address)
- By email (if the candidate has provided an email address)
- In the employment application materials
NYC LL144 Penalties
The DCWP has been actively enforcing NYC LL144 since July 2023. There is no cure period.
| Violation | Penalty | Cure Period |
|---|---|---|
| First violation | $500 per day | None |
| Subsequent violations | $1,500 per day | None |
| Injunctive relief | DCWP may seek court order to stop AEDT use | N/A |
Penalties accrue per day of non-compliance, with no cap on total penalties. A company using a non-compliant AEDT for 30 days could face $15,000-$45,000 in fines. The DCWP has already issued violations to multiple companies.
Deterministic Bias Detection for NYC LL144
Subodh KC's Zenodo publication addresses the reproducibility requirements that auditors need — why deterministic methods matter more than accuracy for audit defensibility.
Bias audits under NYC LL144 must produce reproducible results. If an auditor runs the same bias assessment twice and gets different results, the audit evidence is undermined. Deterministic methods produce identical results on repeated runs — which is critical for audit defensibility.
Key insight from the paper:
Probabilistic or AI-generated bias assessments may produce different results on each run due to random initialization, sampling, or model stochasticity. This makes them unsuitable for regulatory audits where reproducibility is essential. Deterministic bias detection methods — using fixed seeds, exact calculations, and transparent logic — produce the same output every time, making them defensible in regulatory proceedings.
NYC LL144 Compliance Checklist
A practical checklist for achieving and maintaining NYC Local Law 144 compliance.
Identify
Audit
Notify
Maintain
Get the NYC LL144 Compliance Checklist
Free NYC LL144 Compliance Checklist
How Subodh KC Can Help
My Zenodo publication on deterministic bias detection for NYC Local Law 144 addresses the reproducibility requirements that auditors need.
AEDT Assessment
Bias Audit Preparation
Compliance Documentation
Contact Subodh KC for NYC LL144 compliance advisory, or explore advisory services.
Frequently Asked Questions
What is NYC Local Law 144?
Who needs to comply with NYC Local Law 144?
What are the NYC LL144 penalties?
What is an AEDT under NYC Local Law 144?
What does a NYC LL144 bias audit require?
When must candidates be notified under NYC LL144?
Does NYC LL144 have a cure period?
How does deterministic bias detection help with NYC LL144?
This guide is for informational purposes and does not constitute legal advice. For jurisdiction-specific compliance guidance, contact Subodh KC for advisory services. Last updated: July 2026.