NYC Local Law 144 and AI Hiring Tools: A Compliance Checklist for Talent Teams

New York City enforces Local Law 144 the same way it enforces any other labor law: through complaints, audits, and fines, not through a one-time certificate you file and forget. A December 2025 audit from the NYC Comptroller found the city's own enforcement had been inconsistent, which sounds like good news for employers until you read the detail. The Comptroller reviewed the same 32 bias audits the Department of Consumer and Worker Protection had already cleared and found potential issues in at least 17 of them. The agency has since agreed to tighten its process. For any enterprise using AI in hiring or promotion decisions in New York City, that means the compliance bar is likely to get higher, not lower, from here.

This checklist walks through what Local Law 144 actually requires, where talent teams most often get it wrong, and the questions worth asking before you take a vendor's compliance claims at face value.

What Local Law 144 covers

Local Law 144 applies to any employer or employment agency using an automated employment decision tool, or AEDT, to screen candidates for hire or evaluate employees for promotion, where the job is based in New York City, tied to an NYC office, or the employer or agency operates in the city.

An AEDT is defined by what it does, not by its marketing name. Under the city's final rules, a tool counts as an AEDT if it uses machine learning, statistical modeling, data analytics, or AI to produce a score, classification, or recommendation, and that output substantially assists or replaces human judgment in one of three ways: the employer relies on it as the sole factor, it's weighted more heavily than any other factor, or it can override a conclusion a person already reached. That threshold catches a lot more tools than most talent teams assume, including scoring and ranking features buried inside an applicant tracking system.

A few things fall outside the definition: resume database searches, outreach tools, and basic calculators or spreadsheets that don't materially affect the decision. But screening at any stage of the hiring or promotion process, not just the final call, is covered.

The compliance checklist

1. Inventory every tool that touches a hiring or promotion decision. This includes AI features inside your ATS, a standalone assessment platform, resume-screening software, and anything a vendor added through a recent product update. If a tool scores, ranks, or flags candidates, assume it needs review until you confirm otherwise.
2. Confirm which tools meet the AEDT definition. Apply the sole-factor, heaviest-factor, and override test above to each one. Document the reasoning, since this is the first thing an investigator or your own counsel will ask to see.
3. Secure an independent bias audit, no more than a year old, for each covered tool. The audit has to be performed by an auditor with no role in developing, using, selling, or financially benefiting from the tool. It must calculate selection or scoring rates and impact ratios across race, ethnicity, sex, and intersectional categories, using real historical usage data where it exists. A vendor's internal testing, however rigorous, does not meet this bar on its own.
4. Publish the audit summary where candidates can find it. The summary needs to include the audit date, the data source, the number of individuals excluded for unknown demographic data, and the selection rates and impact ratios themselves, not just a pass or fail conclusion. It has to live on the employment section of your website or be reachable through a clear link from there.
5. Give candidates and employees at least 10 business days' notice. They need to know an AEDT is in use, which qualifications or characteristics it assesses, and how to request an accommodation or an alternative process. For external hiring, this can run through the job posting or your careers page. For promotion decisions, a written internal policy can satisfy the requirement.
6. Keep records of all of the above, and revisit them on a schedule. An audit older than a year is no longer valid. A notice process that worked for one job posting template may not cover a new one. Treat this as a recurring compliance task tied to your audit calendar, not a box checked once at implementation.

Why "the vendor handles it" isn't a complete answer

It's common for talent teams to assume a vendor's compliance claims transfer directly to the employer. They don't. Local Law 144 places the obligation on the employer and the employment agency using the tool, not on the company that built it. A vendor can commission or support a bias audit, but you're the one accountable for whether that audit meets the law's requirements, whether the summary is posted correctly, and whether candidates received timely notice.

That distinction matters more now that the Comptroller's audit has shown gaps can slip through even after a city agency has reviewed them. Before relying on a vendor's bias audit, it's worth asking for the full report, not just a badge or a one-line claim, and confirming the auditor's independence, the data source used, and the date of the most recent audit. 15 Essential Questions to Ask When Evaluating AI in Talent Acquisition goes deeper on what to ask any AI hiring vendor before you commit, including how to test their traceability and explainability claims rather than taking them on faith.

New York City isn't the only jurisdiction moving in this direction. Other states and the European Union have introduced or proposed their own rules for AI used in employment decisions, generally built around similar ideas: independent testing, transparency with candidates, and a documented audit trail. A compliance process built around Local Law 144's requirements today puts you ahead of that broader trend, not just current with one city's law.

Where Vervoe fits

Vervoe's role-based assessments are designed around the same principle Local Law 144 is built on: a hiring decision should trace back to evidence, not a black box. Every score connects to a specific, job-relevant task, so a candidate, a hiring manager, or a legal team can see exactly why a result came out the way it did. Vervoe's assessments undergo an annual independent bias audit performed by Holistic AI, with results published for review.

None of this replaces your own compliance process. The law places the obligation on the employer, and a vendor's audit, however rigorous, is one input into the inventory, review, and documentation work above, not a substitute for it. This article is general information, not legal advice. For your specific obligations under Local Law 144 or any other hiring regulation, talk to counsel.

Next steps

Start with the inventory. Most Local Law 144 exposure comes from tools nobody flagged as an AEDT in the first place, not from a known tool with a missing audit. Once you know what's covered, the audit, posting, and notice steps follow a defined sequence you can build into a repeatable compliance calendar.

If you are checking assessment vendors against this list, you can review how Vervoe approaches trust and security in our trust center, or book a demo and walk through your questions with our team.

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