NYC Local Law 144 AI Hiring Bias Audit

NYC's Local Law 144 applies based on where a job candidate lives, not where your business is headquartered. If your AI hiring tool evaluates even one candidate who resides in New York City, the law's bias audit and notice requirements apply to that evaluation, regardless of whether your business has any physical presence in the city at all.

The plain-English answer

If any candidate you're evaluating with an AI screening tool lives in New York City, even for a fully remote role with your business based elsewhere, Local Law 144 applies to that evaluation. The law targets the candidate's residence, not your company's location, which is the single most commonly misunderstood part of it. A business with zero NYC employees or offices can still be fully in scope the moment it screens a resident applicant.

Why this matters for your business

A 20-person remote-first company hiring nationally is exactly the kind of business likely to trigger this law without realising it, remote hiring pools routinely include NYC residents, and there's no obvious signal in the hiring process that flags when the law applies unless someone is specifically checking candidate location against it.

The penalty structure compounds the risk of not knowing: each day an AEDT operates without a current bias audit is treated as a separate violation, and each candidate who doesn't receive the required notice is also a separate violation. A business that's been using an AI screening tool for months without realising NYC candidates were in the mix can accumulate exposure quickly, even though no single decision was made with any bad intent.

What Local Law 144 actually requires

The law covers what it calls Automated Employment Decision Tools, AEDTs, systems that use machine learning, statistical modelling, or similar techniques to substantially assist or replace a human decision in screening or evaluating candidates or employees. Three specific obligations apply to any employer or employment agency using an AEDT to evaluate NYC-resident candidates or employees: commissioning an independent annual bias audit, publicly posting a summary of the audit results on the employer's website, and giving candidates at least 10 business days' notice before the tool is used, along with information about what data it uses.

The bias audit itself has specific requirements: it must be conducted by an auditor genuinely independent of the tool's development or use, and it must test for disparate impact across protected categories, calculating a selection rate for each group and comparing it against the highest-scoring group's rate as an impact ratio. Enforcement has been active, though a December 2025 New York State Comptroller review found the city's Department of Consumer and Worker Protection had historically been more reactive and complaint-driven than proactive, with the department committing to more active enforcement going forward, worth knowing if you've been assuming light enforcement means low real risk.

What this looks like in practice

Picture the HR manager at the remote-first company, running every applicant through an AI screening tool with no location-specific process at all. The assumption, reasonable-sounding but wrong, is that a New York City law simply doesn't apply to a business with no New York office.

Realising the law is triggered by candidate residence changes the process: the HR manager commissions an independent bias audit of the AI tool, covering the categories the law requires, posts the summary publicly, and adds a simple step to the application flow that flags NYC-resident candidates and issues the required 10-business-day notice before the AI tool evaluates them. The fix doesn't require abandoning the AI tool, it requires building the specific compliance layer the law expects around it.

What you can do about it

A practical checklist if your hiring process could ever touch an NYC resident:

• Confirm whether your AI screening or evaluation tool counts as an AEDT under the law's definition, most genuine AI-driven screening or ranking tools do.
• Commission an independent annual bias audit from an auditor with no financial or employment relationship with your business.
• Publish a public summary of the audit results on your website.
• Build a process to identify NYC-resident candidates and give them the required 10 business days' notice before the AEDT evaluates them.
• Don't assume your business is out of scope just because it isn't based in New York City, check based on candidate residence specifically.

For the separate but related question of whether your AI hiring tool could create Title VII liability beyond this specific law, see our guide on EEOC guidance on AI hiring and adverse impact.

Related reading: our free AI acceptable use policy template and our AI governance by region.

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