Find every hiring tool that needs a bias audit. Then keep the audit cycle on track.
New York City's Local Law 144 has been enforced since 5 July 2023. It applies to automated employment decision tools used on NYC candidates and employees. GhostAudit finds those tools and tracks what each one owes.
- Applies nowAnnual bias audit and candidate notice
Annual independent bias audit, public summary, and 10-business-day notice before AEDT use.
- Enforced since
- 5 July 2023
- Enforced by
- NYC DCWP
- Bias audit
- Independent, every year
- Candidate notice
- 10 business days before use
Four duties for employers that use automated tools in hiring or promotion.
Local Law 144 of 2021, with rules from the Department of Consumer and Worker Protection (6 RCNY § 5-300 and following), applies to employers and employment agencies that use an automated employment decision tool (AEDT) to substantially assist hiring or promotion decisions for New York City candidates or employees. They must:
- 01obtain an independent bias audit of the tool within one year before using it, and annually thereafter;
- 02publish a summary of the most recent bias audit results and the tool's distribution date;
- 03notify candidates or employees at least 10 business days before use, including the job qualifications the tool assesses;
- 04provide information on how to request an alternative selection process or accommodation.
Civil penalties are $500 for a first violation and $500 to $1,500 for each subsequent violation. Each day of non-compliant use is a separate violation.
Enforcement has been criticised as weak. The obligations have not changed.
In December 2025 the New York State Comptroller published an audit of how Local Law 144 is enforced, and found enforcement weak. DCWP continues complaint-based enforcement.
That finding describes the regulator, not the law. The duties apply as written, penalties accrue per day of use, and a published audit summary is something candidates, journalists and plaintiffs' lawyers can check for themselves. Other jurisdictions are also converging on hiring: Illinois HB 3773 has applied since 1 January 2026, Colorado's SB 26-189 covers employment decisions from 1 January 2027, and employment is an Annex III high-risk area under the EU AI Act from 2 December 2027.
The hard part is knowing which tools are AEDTs.
HR technology changes quickly, and screening or ranking features arrive inside products that were bought for something else. A recruiter may also start using a general AI assistant to shortlist candidates without anyone deciding that it should happen.
GhostAudit approaches this from both sides. Discovery finds AI tools through Google Workspace, Microsoft 365, Okta, code and endpoint sensors. The inventory records which systems are used in employment decisions; those are matched to Local Law 144 directly. General-purpose tools that are used by people in HR are flagged as potential matches, with a prompt to confirm that they are not used for hiring or promotion decisions.
- Employment-use systems matched to Local Law 144, with the reason
- AI tools used by the HR department flagged for confirmation
- Usage data showing who is actually using each tool, where your identity mode allows
Example workspace. Names and figures are illustrative.
- Vendor
- HireVue
- Owner
- People operations · A. Moreau
- Purpose
- Ranks applicants for customer-support roles against the posted requirements
- Affects
- Job applicants in the EU, New York City and Colorado
- Data
- Restricted · personal data
- Human oversight
- Recruiter reviews every ranked list before contact
- Risk tier
- High
- Last assessed
- 6 Nov 2026 · next review in 90 days
- EU AI Act · Annex III high risk · matched on employment useFrom 2 Dec 2027
- NYC Local Law 144 · matched on employment useIn force
- Colorado SB 26-189 · matched on consequential decisionFrom 1 Jan 2027
Five requirements per tool, and an annual cycle.
The GhostAudit Local Law 144 assessment tracks five requirements for each tool: the independent bias audit, the public audit summary, candidate notice, the notice of qualifications and characteristics assessed, and the data disclosure. For each you record status and evidence, such as the audit report, the URL of the published summary and the notice wording.
The bias audit obligation recurs annually, and the tracker treats it as recurring, so the next audit shows up as a deadline.
To be clear about the boundary: GhostAudit does not perform bias audits. The law requires an independent auditor. GhostAudit keeps track of which tools need one, when, and where the evidence is.
| §20-871(a)(1) | Independent bias audit An independent auditor has completed a bias audit of the AEDT within one year before use. |
| §20-871(a)(2) | Public audit summary A summary of the most recent bias audit results and the AEDT distribution date is published on the employment section of the website. |
| §20-871(b)(1) | Candidate notice Candidates residing in NYC are notified at least 10 business days before use that an AEDT will be used. |
| §20-871(b)(2) | Qualifications and characteristics notice Candidates are told the job qualifications and characteristics the AEDT will assess. |
| §20-871(b)(3) | Data disclosure Information on the type, source and retention policy of data collected for the AEDT is available. |
Read the official texts
- NYC LL 144: official textnyc.gov
- NY State Comptroller: Enforcement of Local Law 144 (Dec 2025)osc.ny.gov
- Illinois HB 3773: official textilga.gov
Dates and statuses on this page were last checked against these sources on 10 November 2026. This is orientation, not legal advice.
Questions
- Does GhostAudit conduct the bias audit?
No. Local Law 144 requires the audit to be independent. We help you identify which tools need one, track the annual cycle and keep the evidence.
- We use a vendor's screening product. Is the audit their job?
The duty is on the employer or employment agency that uses the tool. Vendors often commission an audit of their product that customers can rely on; you still need to make sure one exists for the tool you use, is recent enough, and is published.
- Does the law apply to us if we are not based in New York City?
It applies to the use of AEDTs for New York City candidates and employees. Whether a particular role or candidate is covered is a question for counsel.
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