Use this checklist to verify compliance for every automated employment decision tool (AEDT) you use for NYC-based positions. Enforcement became proactive in January 2026 and the first fines have been issued — this is no longer a paper-only law.
Coverage
Inventory every AI-assisted tool used in hiring or promotion (screeners, rankers, scorers, chatbots).
Confirmed which tools qualify as AEDTs (ML/statistical, substantially assist or replace discretionary decisions).
Identified which positions are NYC-based, including remote roles open to NYC residents.
Bias audit
Current independent bias audit completed within the last 12 months (selection rates, impact ratios, four-fifths assessment per DCWP Final Rules).
Auditor is independent — no financial interest in the tool, vendor, or employer.
Score-based tools assessed with median-threshold scoring rates.
Re-audit calendar set for 12 months from the audit date.
Public summary
Summary of the most recent bias audit posted publicly on the careers site.
Summary includes tool identification and per-category selection rates / impact ratios.
Summary URL is linked from job postings that use the AEDT.
Candidate notice
Notice provided at least 10 business days before AEDT use.
Notice identifies the tool and the job qualifications/characteristics it evaluates.
Alternative selection process offered and contact provided.
Penalty awareness
Understood exposure: $500 first violation, $500–$1,500/day after, per tool (180 days × 1 tool ≈ $67,500–$270,000).
Assigned a compliance owner and documented decisions.