New York City Local Law 144 — AI Hiring Bias Audit Mandate

New York City's Local Law 144, enacted in December 2021 and enforced from July 2023, requires any employer using an Automated Employment Decision Tool (AEDT) — algorithmic software used to screen, score or rank candidates — to commission an independent annual bias audit. The audit must calculate selection and scoring rates broken down by sex, race/ethnicity and their intersections, publish a summary on the employer's website, and notify candidates that an AEDT is in use with the right to request an alternative process. It was the first law globally to mandate algorithmic bias audits for hiring.

Independent evidence of the law's real-world performance is mixed to poor. A peer-reviewed FAccT 2024 study ('Null Compliance'), in which 155 student investigators tracked 391 New York employers, found only 18 (about 4.6%) had posted a bias audit report and just 13 (about 3.3%) had posted the required transparency notice. The researchers coined the term 'null compliance' because the law gives employers wide discretion over whether their tool is even in scope, making it impossible to tell missing disclosures apart from lawful exemptions.

A New York State Comptroller audit released in December 2025 corroborated this picture at the regulator level: it found 75% of test calls to the city's 311 hotline about AEDT complaints were misrouted and never reached DCWP, that DCWP's own review of 32 posted bias audits found only one compliance issue where the Comptroller's auditors found at least 17, and that DCWP received only two formal AEDT complaints in the two-year audit period despite penalties of $500–$1,500 per violation being available. The Comptroller concluded DCWP's enforcement was 'ineffective.'

The law remains significant as a first-mover model that explicitly frames algorithmic hiring bias as a sex- and race-equity issue, and it has shaped subsequent AI-hiring proposals elsewhere. But the documented evidence to date is a cautionary case: transparency-only, employer-self-scoped regulation has not yet produced verifiable compliance or measurable bias reduction.

Read the full analysis: https://www.nyc.gov/site/dca/about/automated-employment-decision-tools.page