NYC Local Law 144: Complete Compliance Checklist
Step-by-step guide to NYC AI hiring bias audit requirements. Avoid $500-$1,500/day penalties. Candidate notifications, approved auditors, public disclosure.
6-Step NYC LL144 Compliance Checklist
Determine if NYC LL144 Applies
- Using AI for resume screening, candidate ranking, or interview analysis
- Position is based in NYC (even if company is not)
- Includes remote positions if employee works from NYC
- Applies to both employers and employment agencies
Conduct Annual Bias Audit
- Hire independent auditor (not vendor or internal team)
- Test for disparate impact on race/ethnicity and gender
- Use historical data from past year (minimum 100 candidates)
- Calculate selection rates and impact ratios
- Audit must be completed within 12 months before use
Publish Audit Results Publicly
- Post on company website (publicly accessible)
- Include: audit date, selection rates, impact ratios
- Publish within 30 days of audit completion
- Keep published for at least 6 months
- Update annually with new audit results
Notify Candidates of AI Use
- Notify at least 10 business days before AI use
- Specify job requirements and qualifications
- Explain data retention and use policy
- Provide alternative selection process option
- Include contact for accommodations
Provide Alternative Selection Process
- Offer human review option for candidates
- Must be available upon request
- Cannot disadvantage candidates who request it
- Document all alternative process requests
Maintain Documentation
- Audit reports and methodology
- Candidate notifications (proof of delivery)
- Alternative process requests and outcomes
- AI tool vendor contracts and specifications
- Keep records for 3 years minimum
Approved Auditor Requirements
NYC LL144 requires independent bias audits. The auditor must have no financial interest in the AI tool being audited.
- Independent third-party auditors (not AI vendor)
- Academic institutions with bias testing expertise
- Specialized AI audit firms (e.g., O'Neil Risk Consulting & Algorithmic Auditing)
- Civil rights organizations with technical capacity
- Must have no financial interest in AI tool being audited
NYC LL144 FAQ
How do I know if my AI tool is subject to NYC LL144?
NYC LL144 applies if: (1) You use AI to screen candidates or make hiring decisions, (2) The position is based in NYC, (3) You are an employer or employment agency in NYC. Examples: AI resume screening, video interview analysis, candidate ranking algorithms. Does NOT apply: Manual review, simple keyword filters, non-automated tools.
What is a bias audit under NYC LL144?
Independent testing for disparate impact on race/ethnicity and gender. Auditor calculates selection rates for each group and compares using impact ratios. Passing threshold: 80% rule (selection rate for protected group must be at least 80% of highest group). Must use historical data from past year with minimum 100 candidates per category.
How much does NYC LL144 compliance cost?
Bias audit: $5K-$25K depending on AI complexity and data volume. Candidate notifications: $0-$500 (email automation). Legal review: $2K-$10K. Total first year: $7K-$35K. Annual ongoing: $5K-$25K (audit renewal). HAIEC tools reduce costs by automating notifications and documentation.
What are the penalties for NYC LL144 violations?
$500-$1,500 per day per violation. Violations include: (1) Using AI without audit, (2) Not notifying candidates, (3) Not publishing audit results, (4) Not providing alternative process. Example: 100 candidates without notification = $50K-$150K per day. Penalties accumulate daily until cured.
Can I use my AI vendor's bias audit?
Only if: (1) Audit was conducted by independent third party (not vendor), (2) Audit used YOUR company's historical data, (3) Audit was completed within past 12 months, (4) Audit tested YOUR specific use case. Vendor audits using generic data or vendor's own data do NOT satisfy NYC LL144. You need company-specific audit.
How often do I need to renew the bias audit?
Annually. Audit must be completed within 12 months before AI use. If you use AI continuously, you need new audit every year. If you modify the AI tool (algorithm changes, new features), you may need new audit sooner. Track audit expiration dates carefully - using expired audit = non-compliance.
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