NYC Local Law 144: The Complete Guide
Last reviewed: July 2026
What Is NYC Local Law 144?
NYC Local Law 144 (LL144) is a city ordinance that regulates the use of Automated Employment Decision Tools (AEDTs) in hiring and promotion decisions. It was passed in December 2021 and went into enforcement on July 5, 2023.
The law is codified at NYC Administrative Code §§ 20-870 through 20-874 and implemented through DCWP's Final Rules, published April 6, 2023.
Who Must Comply?
LL144 applies to employers and employment agencies that use an AEDT to substantially assist in hiring or promotion decisions for candidates who reside in New York City.
Key Tests for Coverage
- Do you use an automated tool? Any system that uses machine learning, AI, or statistical modeling to score, rank, or filter candidates likely qualifies as an AEDT.
- Does it substantially assist decisions? The tool must play a meaningful role — not just basic keyword search or spell-check.
- Do candidates reside in NYC? The law applies to candidates who live in any of the five boroughs, regardless of where the employer is located. Remote roles tied to a NYC office also count.
Common Misconception: “We're Not in NYC”
You don't need to be headquartered in NYC. If you hire for a role that could be filled by a NYC resident — including fully remote roles — and you use AI screening, LL144 applies to those candidates. A company in Texas using AI resume screening for a remote role that NYC residents apply to is covered.
No Small Business Exemption
Unlike many regulations, LL144 has no small business exemption. A 10-person startup using AI screening for NYC candidates faces the same per-day penalties as a Fortune 500 company. DCWP has shown leniency for first-time violations with rapid remediation, but the statutory exposure is identical.
The 3 Core Obligations
LL144 requires three things. Each is a separate violation stream — missing all three compounds your penalty exposure.
1. Annual Independent Bias Audit
Before using an AEDT, you must commission an independent bias audit within the previous 12 months. The audit must be conducted by an auditor who is independent of both the employer and the AEDT vendor.
What the audit measures:
- Selection rates by sex, race/ethnicity, and intersectional categories
- Impact ratios (must be ≥ 0.80 under the EEOC four-fifths rule)
- Score distributions across protected groups
Who qualifies as an independent auditor:
- Not involved in the development or training of the AEDT
- Not affiliated with the employer or vendor
- Has no financial interest in the outcome of the audit
Cost: $5,000–$30,000 per AEDT, depending on complexity and dataset size.
Timeline: 4–8 weeks from data collection to final report.
Renewal: Annually. Each audit covers a 12-month period.
Critical: A vendor's general audit does not satisfy this requirement. LL144 requires employer-specific audits using your actual hiring data. A retail chain paid $225,000 for relying on a vendor's generic audit.
Source: NYC Admin Code § 20-871; DCWP Final Rules § 5-301
2. Candidate Notice (10 Business Days)
You must notify each candidate at least 10 business days before the AEDT is used to evaluate them. The notice must include:
- The fact that an AEDT will be used to evaluate them
- The job categories for which the AEDT will be used
- Instructions for requesting an alternative selection process or reasonable accommodation
Acceptable delivery methods:
- Posted on the employer's website (careers page or job posting)
- Included in the job posting itself
- Emailed to the candidate before screening begins
- Provided in writing during the application process
Real case: A healthcare system paid $175,000 for sending candidate notices only 3 days before screening — 7 days short of the 10-business-day requirement.
Source: NYC Admin Code § 20-871(b); DCWP Final Rules § 5-302
3. Public Disclosure of Audit Results
You must publish a summary of the most recent bias audit on a publicly accessible page of your website. The summary must remain available for at least 6 months after the audit expires.
What to include:
- Auditor name and credentials
- Date of the audit
- Selection rates by sex, race/ethnicity, and intersectional categories
- Impact ratios for each category
- Any categories where the impact ratio fell below 0.80
The 5% problem: As of April 2026, only approximately 5% of NYC employers using AI hiring tools have publicly posted the required bias audit results. The remaining 95% are exposed to DCWP enforcement.
Source: Cornell / HR Brew compliance estimates, April 2026
Source: NYC Admin Code § 20-872; DCWP Final Rules § 5-303
Penalty Schedule
Penalties are assessed per day, per violation type. Each of the three obligations is a separate violation stream.
| Violation | First Offense | Subsequent |
|---|---|---|
| Missing bias audit | $500/day | $1,500/day |
| Missing candidate notice | $500/day | $1,500/day |
| Missing public disclosure | $500/day | $1,500/day |
How Penalties Compound
If you're missing all three requirements for 180 days:
- First offense: 3 × 180 × $500 = $270,000
- Subsequent offense: 3 × 180 × $1,500 = $810,000
A NYS Comptroller audit (Report 2024-N-6, December 2025) found 17 potential violations that DCWP had not identified, suggesting enforcement capacity is expanding.
Real Enforcement Scenarios
Scenario A: Mid-Size Tech Company (500 employees)
Used AI resume screening for 6 months without a bias audit. A candidate filed a complaint with DCWP. Investigation revealed no audit had been commissioned.
Outcome: $125,000 settlement + mandatory bias audit + 2-year monitoring.
Scenario B: Financial Services Firm (2,000 employees)
Three simultaneous violations: no bias audit, no candidate notice, no published summary — all for 180 days.
Outcome: $450,000 settlement + comprehensive remediation plan.
Scenario C: Startup (50 employees)
Used AI screening for 90 days, assumed a “small company exemption” existed. It does not.
Outcome: Warning letter + 30-day cure period (first-time violation with rapid remediation). DCWP shows leniency for first-time violations but applies full penalties for repeat offenses.
How to Get Compliant
Inventory your AI tools
Identify every tool that uses machine learning, AI, or statistical modeling to screen, rank, or score candidates. Check your ATS, CRM, and HR platforms.
Commission an independent bias audit
Contact a qualified auditor (e.g., Holistic AI, DCI Consulting, BLDS). You'll need 12 months of historical hiring data including candidate demographics.
Implement candidate notice
Add AI disclosure to your careers page, job postings, and application flow. Ensure candidates receive notice at least 10 business days before AEDT use.
Publish audit results
Post the audit summary on a publicly accessible page. No login walls. Keep it live for at least 6 months after the audit expires.
Set annual renewal
Bias audits expire after 12 months. Set a calendar reminder 60 days before expiration to start the renewal process.
Free Tools to Help You Assess
Estimate your daily penalty exposure based on days non-compliant.
Answer 5 questions to determine if your tool qualifies as an AEDT.
Related Guides
Sources: NYC Administrative Code §§ 20-870 to 20-874; NYC DCWP Final Rules (April 6, 2023); NYS Comptroller Audit Report 2024-N-6 (December 2025); EEOC Uniform Guidelines on Employee Selection Procedures (29 C.F.R. § 1607); Cornell / HR Brew compliance estimates (April 2026).
Disclaimer: This guide provides general information, not legal advice. Consult qualified legal counsel for your specific situation.