New York City's Local Law 144 — Mandatory Bias-Audit Disclosure for Automated Hiring Tools, and Its Enforcement Gap

Local Law 144 requires any employer using an 'automated employment decision tool' (AEDT) — software that substantially assists or replaces human judgement in hiring or promotion decisions — on New York City-based candidates to commission an independent bias audit and publicly post a summary of the results, alongside a notice to candidates. The law was enacted in 2021, took effect on 1 January 2023, and enforcement by DCWP began on 5 July 2023.

The law's aim is to make the use of automated hiring tools more transparent and accountable through mandatory independent audits and public disclosure.

Enforcement is carried out by the NYC Department of Consumer and Worker Protection (DCWP), which reviews complaints and employer compliance with the audit-posting and candidate-notice requirements.

An audit by the New York State Comptroller, published 2 December 2025 and covering July 2023 to June 2025, found DCWP received only two AEDT complaints in the entire period, reviewed the websites and bias audits of 32 companies, and identified just one instance of non-compliance — while the Comptroller's own review of the same 32 companies found at least 17 instances of potential non-compliance. The audit attributed the gap to DCWP not investigating whether its own complaint intake process worked and not applying the formal review procedures its own office had created. A separate academic study that checked 391 employers found only 18 had posted a bias-audit summary and 13 had posted the required candidate notice.

Local Law 144 remains the first binding public-disclosure regime of its kind for AI hiring tools, and its design — mandatory independent audits plus public posting — has influenced later proposals elsewhere. But the Comptroller's and academics' findings make it a documented cautionary case: passing a transparency law does not by itself produce transparency without matching enforcement capacity.