Public Disclosure: Publishing Your Audit
Last reviewed: July 2026
Source: Cornell / HR Brew compliance estimates, April 2026
Where to Post
The audit summary must be posted on a publicly accessible page of your website. This means:
- No login walls or paywalls
- No buried links — must be reasonably discoverable
- Accessible to anyone with the URL
- Available 24/7 (no temporary takedowns)
Recommended locations: Careers page, “Compliance” or “Transparency” page, or a dedicated “AI Hiring Disclosure” page linked from your footer.
What to Include
The published summary must include:
- Auditor name and credentials — Who conducted the audit
- Date of the audit — When it was completed
- Selection rates — By sex, race/ethnicity, and intersectional categories
- Impact ratios — For each category, compared to the highest-selected group
- Flagged categories — Any where the impact ratio fell below 0.80
Source: NYC Admin Code § 20-872; DCWP Final Rules § 5-303
How Long to Keep It Published
The summary must remain publicly available for at least 6 months after the audit expires. Since audits are valid for 12 months, the summary should stay published for approximately 18 months total (12 months of validity + 6 months post-expiration).
Why 95% Haven't Complied
- Unawareness — Many employers don't know LL144 exists or applies to them
- Vendor confusion — Employers assume the vendor handles disclosure (they don't)
- Cost barrier — Bias audits cost $5K–$30K, and some employers delay
- Embarrassment — Employers fear publishing results that show bias
- No proactive enforcement (until now) — DCWP was complaint-driven until January 2026
Key insight: Having an audit that finds bias is better than having no audit. The law requires you to conduct the audit and publish the results — it does not require the results to show no bias. Publishing results with flagged categories and a remediation plan demonstrates good faith compliance.
What Happens If You Don't Publish?
Missing public disclosure is a separate violation stream from missing the audit itself. Even if you've conducted a bias audit, failing to publish the summary carries the same per-day penalty: $500 (first offense) or $1,500 (subsequent offense).
With DCWP's shift to proactive investigations in January 2026, enforcement agents can simply visit your website to check for compliance. No complaint is needed.
Related Guides
Sources: NYC Admin Code § 20-872; DCWP Final Rules § 5-303; Cornell / HR Brew compliance estimates (April 2026).
Disclaimer: This guide provides general information, not legal advice.