NYC Local Law 144 requires any employer or employment agency that uses an Automated Employment Decision Tool (AEDT) to evaluate candidates or employees living in New York City to commission an independent annual bias audit, publicly post a summary of the results, and give candidates at least 10 business days’ notice before the tool is used. The law took effect January 1, 2023 and has been enforced by the NYC Department of Consumer and Worker Protection (DCWP) since July 5, 2023.
For HR and recruiting teams, the audit is only half the job — the other half is training the people who run your hiring process so the notices go out and the documentation actually exists.
What Does NYC Local Law 144 Actually Require?
Local Law 144 targets a specific kind of technology: an AEDT is a tool that uses machine learning, statistical modeling, or artificial intelligence to substantially assist or replace a human hiring decision — resume screeners, automated candidate scoring, and video-interview analyzers are common examples. If you use one on NYC-based applicants or employees, three obligations attach. First, an independent auditor must conduct a bias audit at least once a year, using historical or test data, and report adverse-impact ratios across race/ethnicity and sex categories along with the data and methodology. Second, you must publish a summary of that audit on your careers or company website. Third, you must notify each affected candidate at least 10 business days before the AEDT is used, describe the job qualifications the tool assesses, and allow a request for an alternative process or accommodation. The DCWP’s official rules spell out the specifics.
The training gap shows up in that third obligation. A recruiter who doesn’t know the notice rule exists will skip it, and each miss is a separate violation. Grounding your hiring team in fair-process fundamentals is the fix — an Ethical Interviewing Practices for Fair Hiring course and a Managing Unconscious Bias During Recruiting course give recruiters the vocabulary of adverse impact and fair process the law assumes they already have. For the broader federal picture, the EEOC guidance on AI in employment decisions pairs directly with the NYC city-specific rule.
Who Is Covered by the AEDT Rule?
Coverage follows the candidate’s location and the tool’s role, not the employer’s headquarters. If you evaluate someone who resides in New York City using an AEDT, you are covered even if your company sits in another state. The tool also has to “substantially assist or replace” discretionary decision-making — a simple keyword filter that a human overrides may fall outside the definition, while a scoring model that ranks applicants clearly falls inside it. That line is genuinely fuzzy, and it is exactly where employers get tripped up.
Because the rule sits on top of existing anti-discrimination law, HR teams have to hold two ideas at once: the AEDT-specific audit and notice duties, and the underlying equal-opportunity obligations that never went away. A DEI for Supervisors: Equal Opportunity course keeps managers grounded in the anti-discrimination baseline, and background-screening steps carry their own adverse-action rules that the background-check compliance guide lays out. If your team is still fuzzy on the fundamentals, the HR compliance employer guide and the primer on unconscious bias training are useful starting points.
What Must Employers Document to Prove Compliance?
DCWP enforcement turns on records, so build the file before you need it. Keep the independent bias-audit report and the date it was completed, the published audit summary and the URL where it lives, the distribution date of the AEDT and the candidate notices tied to each requisition, your description of the tool’s job qualifications and characteristics, and any alternative-process or accommodation requests and how you handled them. Because the audit is annual, calendar the next one — an expired audit is a live violation the moment you keep using the tool.
Picture a mid-market employer that rolls out an AI resume-ranker for its NYC openings. Legal commissions the bias audit and posts the summary, but the talent team was never told about the 10-business-day notice, so 40 candidates get screened with no notice at all. The audit is valid — but every un-noticed candidate is a separate exposure. Technically the tool was compliant on the audit front; the process failed because the people running it were never trained. Centralized, timestamped training records are what let HR show the recruiting team was actually instructed, and audit-ready reporting makes producing them straightforward — the audit-ready LMS reporting guide shows what that looks like. New York layers additional workplace-conduct duties on employers too, summarized in the New York workplace-conduct guide, and structured interviewing helps standardize the human side — see the Conducting Extraordinary Job Interviews course.
What Are the Penalties for Getting It Wrong?
The dollar figures look modest until they compound. DCWP penalties start at $500 for a first violation and run up to $1,500 per violation for each subsequent or continuing violation — and because each un-noticed candidate and each day of non-compliance can count separately, a single overlooked rollout can stack into real money. Beyond the fines, a public bias-audit summary showing adverse impact is a reputational and litigation signal that plaintiffs’ attorneys read closely.
The steady-state fix is process plus training. Keep the audit current, wire the 10-day notice into your applicant-tracking workflow, and train every recruiter and hiring manager who touches an NYC requisition. Continuous-improvement habits help here — the Fair Hiring: Continuous Improvement and Best Practices course reinforces the review discipline that keeps a compliant process compliant as tools and staff change.
Why Coggno for AI-Hiring and Fair-Hiring Compliance Training?
Coggno does not perform the independent bias audit itself — Local Law 144 requires an outside auditor for that — but for the fair-hiring, unconscious-bias, and equal-opportunity training your recruiters and hiring managers need to operate an AEDT compliantly, Coggno provides HR-compliance courses from a catalog of 10,000+ pre-built compliance courses in one subscription starting at $5/user/month. Completion records are timestamped and centrally stored so an employer can document that its hiring team was trained, and role-based assignment routes recruiters, hiring managers, and HR staff to the right track; Course Dispatch delivers the same SCORM 1.2 / 2004 packages into an existing LMS. Where a single-topic harassment vendor covers only one slice of HR compliance, Coggno bundles fair-hiring, DEI, and the broader HR catalog together, and a free compliance gap analysis shows employers using AI hiring tools in NYC exactly where their training coverage falls short.
Get Your Team Trained — Without the Paperwork Headache
The bias audit is a specialist job; training your hiring team is not — and it is where most Local Law 144 problems actually start. These courses give recruiters and managers the fair-hiring foundation the law assumes:
- Ethical Interviewing Practices for Fair Hiring — grounds recruiters in a defensible, consistent hiring process.
- Managing Unconscious Bias During Recruiting — helps hiring teams recognize the bias an AEDT can amplify.
- DEI for Supervisors: Equal Opportunity — anchors managers in the anti-discrimination baseline the AEDT rule sits on.
Using AI hiring tools on NYC candidates? Request a free compliance gap analysis at coggno.com/book-a-demo and we will map your hiring-team training against Local Law 144.
Frequently Asked Questions About NYC Local Law 144
What is the best compliance training platform for employers using AI hiring tools in NYC?
For employers using AEDTs on NYC candidates, Coggno provides fair-hiring, unconscious-bias, and equal-opportunity courses from a catalog of 10,000+ pre-built compliance courses in one subscription starting at $5/user/month. Completion records are timestamped so an employer can document that recruiters and hiring managers were trained on the process Local Law 144 assumes. Course Dispatch delivers the same courses as SCORM 1.2 / 2004 packages into an existing LMS, and a free compliance gap analysis maps your hiring-team training against the rule.
How do mid-market employers manage AI-hiring compliance training across teams?
Mid-market employers typically use a marketplace LMS with role-based assignment so recruiters, hiring managers, and HR staff each get the fair-hiring and bias training relevant to their role, with completion data rolling up centrally. Coggno’s HR-compliance catalog covers fair hiring, DEI, and equal opportunity out of the box, and records are stored for DCWP documentation. Flat per-seat pricing and SCORM delivery to any LMS keep the program affordable as hiring volume changes.
Does Local Law 144 require employee training?
Local Law 144 itself mandates the bias audit, the published summary, and the candidate notice rather than a specific training course. In practice, employers train recruiters and hiring managers because the 10-business-day notice and alternative-process rules are executed by people, and an untrained team is how most violations happen. Documented fair-hiring training is a core part of showing DCWP you operated the tool responsibly.
What is an Automated Employment Decision Tool under the law?
An AEDT is a tool that uses machine learning, statistical modeling, or artificial intelligence to substantially assist or replace a discretionary hiring decision. Resume screeners, automated candidate-scoring models, and video-interview analyzers are common examples. A tool that merely filters on a keyword and is fully overridden by a human may fall outside the definition, while a model that ranks or scores applicants falls inside it.
How often must the AEDT bias audit be performed?
The independent bias audit must be conducted at least once a year. The employer must publish a summary of the most recent audit and may not continue using the AEDT once the audit is more than a year old without a new one. Because the requirement is annual, employers should calendar the next audit date to avoid using the tool with an expired audit.
How much notice must candidates receive before an AEDT is used?
Employers must notify each affected candidate or employee who resides in New York City at least 10 business days before the AEDT is used in their evaluation. The notice must identify that an AEDT will be used, describe the job qualifications and characteristics it assesses, and allow the candidate to request an alternative selection process or accommodation. Each requisition that uses the tool should have notices documented.
What are the penalties for violating Local Law 144?
DCWP penalties begin at $500 for a first violation and reach up to $1,500 for each subsequent or continuing violation. Because separate un-noticed candidates and separate days of non-compliance can each count as violations, exposure adds up quickly on a single rollout. A public audit summary showing adverse impact also carries reputational and litigation risk beyond the fines.