DCWP moved to proactive investigations in January 2026 and the first fines have been issued. If your company is asked about an AEDT, here is the evidence file you need to assemble — and how long it takes to create.
The three evidence pillars
Current bias audit (completed within the last 12 months)
The audit report itself, with completion date
Independent auditor identification (no financial interest in tool/vendor/employer)
Methodology: selection rates, impact ratios, four-fifths per DCWP Final Rules
Posted public summary
The summary published on your careers site, with the URL
It must reflect the most recent audit (posting last year's summary with this year's audit is a gap)
Candidate notice records
Notice language used (10 business days before AEDT use)
Evidence it was provided: email logs, ATS notice timestamps, alternative-process contact
Building the compliance file (1-2 days)
Inventory: list every AEDT and the positions/states where it is used.
Verify dates: audit completion date vs. today. Expired? See our renewal guide.
Gather artifacts: audit report, summary URL, notice templates and logs.
Run a fresh analysis if the audit is stale (72 hours with automated analysis).
Store centrally: one folder with the three pillars, dated.
Common gaps found in the Comptroller audit
The Dec 2025 State Comptroller audit (2024-N-6) found 17 potential violations in 32 companies — DCWP found one. Typical gaps: missing notice records, stale audits, summaries that don't match the current audit, and no documented auditor independence. All of these are fixable in days once you know what to collect.
What you need vs. what it costs
Fresh statistical analysis: $299–$1,500, 72 hours (ComplyLens or equivalent).
Independent auditor sign-off (for full legal effectiveness): coordinated separately.