ComplyLens — LL144 Guide

Automated Employment Decision Tool (AEDT) Audit, Explained

An AEDT audit is the statistical examination New York City's Local Law 144 requires for automated tools that screen, rank, or score job candidates. Here's what it is — and isn't.

What counts as an AEDT

An AEDT is a tool that uses machine learning, statistical modeling, or data analytics to substantially assist or replace discretionary decision-making in hiring or promotion. Common examples: AI resume screeners, interview-ranking systems, and skills-assessment scorers. A plain keyword filter or ATS database search is generally not an AEDT.

What the audit measures

Who performs it

The audit must be independent — performed by someone with no financial interest in the tool, its vendor, or the employer (DCWP Final Rules). The auditor works from the tool's outputs on real candidate data; source code access is not required.

What happens if you skip it

DCWP moved to proactive investigations in January 2026 and the first fines have been issued. Penalties run $500 for the first violation and $500–$1,500 per day after, per tool. Six months of non-compliant use across one tool is a $67,500–$270,000 exposure range.

Getting compliant

Automated statistical analysis (72-hour turnaround) plus independent sign-off is the fastest path. Start with a self-assessment toolkit to confirm coverage, then order the analysis.

Start with the Readiness Toolkit — $299