Local Law 144 (LL144) requires New York City employers using automated employment decision tools (AEDTs) in hiring or promotion to obtain an annual independent bias audit, publish a summary, and notify candidates. Enforcement has shifted from paper-only to proactive investigations since January 2026, with the first fines issued. This guide covers everything you need.
You are covered if you use an AEDT — a machine-learning or statistical tool that substantially assists or replaces discretionary screening, evaluation, or ranking — for positions based in NYC, including remote roles open to NYC residents. Your company's headquarters location does not matter.
| Obligation | Requirement | Deadline |
|---|---|---|
| Bias audit | Independent audit within the last 12 months: selection rates and impact ratios by protected category, four-fifths assessment | Annual, before use |
| Public summary | Summary of the most recent audit posted on your website | Continuous while in use |
| Candidate notice | 10 business days' notice before AEDT use, with option to request alternative process | 10 business days before use |
Per DCWP Final Rules (6 RCNY Subchapter T):
Penalty structure (per-day, per-tool): $500 first violation; $500–$1,500 each subsequent day.
Enforcement status: The Dec 2025 State Comptroller audit (2024-N-6) found 17 potential violations in 32 companies. DCWP moved to proactive investigations in January 2026; the first fines were issued in late 2025/2026. Law firms advise expecting tighter enforcement through 2026.
| Compliant (automated analysis + audit) | Non-compliant (180 days, 1 tool) | |
|---|---|---|
| Cost | $299–$2,500 | $67,500–$270,000 exposure (lower–upper bound) |
| Risk | Low | Enforcement action, daily accrual |
Start with the Readiness Toolkit — $299
Does LL144 apply to remote roles? Yes — any NYC-based position, including remote roles open to NYC residents.
Is my ATS an AEDT? If it uses machine learning to screen, rank, or score candidates, almost certainly yes.
Can I do the audit myself? The audit must be performed by an independent auditor with no financial interest in the tool or employer.
What about Illinois/Colorado/California? Multi-state obligations are expanding (IL HB 3773, CO AI Act, CA ADMT). The same statistical analysis supports multiple jurisdictions.