New York City Local Law 144 — Automated Employment Decision Tools Compliance Checklist 2026
NYC Local Law 144 (Int. 1894-A) requires any employer or employment agency in New York City that uses an automated employment decision tool (AEDT) in hiring or promotion decisions to conduct annual in…
Maximum penalty: $500 per violation; $1,500 per day for continuing violations (enforced by NYC Dept. of Consumer and Worker Protection)
Enforcement: July 5, 2023
Complete each item below to achieve compliance. Use ComplianceIQ to generate all required documentation automatically.
Regulatory Requirements
1. Annual Independent Bias Audit
Conduct an annual bias audit of each AEDT by an independent third party. The audit must assess disparate impact on candidates by sex, race/ethnicity, and intersectional categories. Audits must be completed within one year before use.
2. Publish Bias Audit Results
Post the bias audit summary on your public website, including the date of the audit, the distribution date of the tool, and the scoring rate for each EEO category. Results must remain online for at least six months.
3. Candidate Notification
Notify all candidates and employees that an AEDT will be used to evaluate them, at least 10 business days before use. Include information on what job qualifications the tool screens for and where to request an alternative process.
4. Alternative Selection Process
Accommodate candidates or employees who request an alternative selection process or accommodation instead of AEDT evaluation.
Implementation Steps
5. Audit all AI tools used in sourcing, screening, ranking, or assessment of candidates
6. Check NYC Local Law 144 applicability (hiring or promoting NYC workers)
7. Check Colorado AI Act (consequential decisions for Colorado residents)
8. Check Illinois AI Video Interview Act for video-based AI screening
9. Review EEOC guidance on AI in employment — disparate impact liability
10. Ensure your hiring AI vendor provides bias auditing and disparity data
11. Create a disclosure notice for candidates explaining AI tool use
12. Implement a process for candidates to request human review of AI decisions
13. Document reasonable accommodations for candidates who cannot use AI-based screening