NYC LL144 Enforcement in 2026: What the Comptroller's Audit Means for Employers

The New York State Comptroller's December 2025 audit (2024-N-6) concluded that DCWP's enforcement of Local Law 144 had been ineffective. In reviewing the same 32 companies DCWP examined, auditors identified at least 17 instances of potential non-compliance — where DCWP found just one. During the first two years of enforcement, only two AEDT complaints reached the agency.

2026: Enforcement is changing

The audit's findings triggered a visible shift. DCWP moved from complaint-driven to proactive investigations in January 2026, and the first fines were issued in late 2025 into 2026 — the era of paper-only enforcement is over. Law firms (DLA Piper among them) are advising clients to expect tighter enforcement through the year.

Penalties under LL144 accumulate daily: $500 for a first violation and $500–$1,500 per day after, per tool. For a company that has been non-compliant since 2023, the exposure math is severe — and the enforcement posture is no longer hypothetical.

The practical takeaway: the compliance clock has been running since July 2023, and the enforcement posture is now tightening. An annual bias audit with a posted public summary is the single requirement that keeps employers out of this exposure.