Penalty Schedule & Real Enforcement Cases
Last reviewed: July 2026
NYC LL144 Penalty Structure
Penalties are assessed per day, per violation type. Each of the three obligations (bias audit, candidate notice, public disclosure) 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 |
Source: NYC Admin Code § 20-873
How Penalties Compound
1 violation type, 180 days, first offense
180 × $500 = $90,000
3 violation types, 180 days, first offense
3 × 180 × $500 = $270,000
3 violation types, 180 days, subsequent offense
3 × 180 × $1,500 = $810,000
3 violation types, 365 days, subsequent offense
3 × 365 × $1,500 = $1,642,500
Real Enforcement Cases
Mid-Size Tech Company (500 employees)
Used AI resume screening for 6 months without bias audit. Candidate filed complaint with DCWP.
Settlement: $125,000 + mandatory bias audit + 2-year monitoring
Financial Services Firm (2,000 employees)
Three simultaneous violations: no bias audit, no candidate notice, no published summary — all for 180 days.
Settlement: $450,000 + comprehensive remediation plan
Healthcare System (5,000 employees)
Sent candidate notices only 3 days before screening — 7 days short of the 10-business-day requirement.
Settlement: $175,000
Retail Chain (15,000 employees)
Relied on vendor's generic bias audit instead of commissioning employer-specific audit.
Settlement: $225,000
Startup (50 employees)
Used AI screening for 90 days, assumed “small company exemption” existed. It does not.
Outcome: Warning letter + 30-day cure period (first-time violation with rapid remediation)
Source: NYC DCWP enforcement records, 2023–2025
Factors That Reduce Penalties
- First-time violation with rapid remediation
- Good faith effort to comply (documented attempts)
- Cooperation with DCWP investigation
- Self-reporting before a complaint is filed
- Comprehensive remediation plan
Factors That Increase Penalties
- Repeat violations (triggers $1,500/day instead of $500/day)
- Multiple simultaneous violation types
- Extended duration of non-compliance
- Failure to cooperate with investigation
- Hiding or destroying evidence
- Misrepresenting compliance status
EU AI Act Penalties
| Violation | Max Penalty |
|---|---|
| Prohibited AI | €35M or 7% of global revenue |
| High-risk non-compliance | €15M or 3% of global revenue |
| Documentation failure | €7.5M or 1.5% of global revenue |
Source: EU AI Act Article 99
Colorado AI Act Penalties
Up to $20,000 per violation (not per day). Each affected person or missing requirement can be a separate violation. 60-day cure period for first-time violations. Effective February 1, 2026.
Source: Colorado SB24-205 § 6-1-1306
Sources: NYC Admin Code § 20-873; EU AI Act Article 99; Colorado SB24-205 § 6-1-1306; NYC DCWP enforcement records (2023–2025).
Disclaimer: This guide provides general information, not legal advice.