NYC Local Law 144: AI hiring law guide

New York City Local Law 144 bars employers and employment agencies from using an automated employment decision tool (AEDT) to screen candidates or employees for jobs in the city unless the tool has had an independent bias audit within the past year, a summary of that audit is public, and candidates received notice at least 10 business days before the tool is used. The city’s Department of Consumer and Worker Protection (DCWP) enforces it.

Important: this is general information, not legal advice. AI hiring rules are changing quickly at the city, state and federal level, and how the law applies depends on the tools you use. We last checked this guide in November 2026. Always confirm how the law applies to your tools and your hiring with an employment lawyer before you rely on it.

Who NYC Local Law 144 covers

It applies to employers and employment agencies that use an AEDT in hiring or promotion in New York City. Per the DCWP’s FAQ, the law covers use “in the city”, meaning a job located at least partly in a New York City office, a fully remote job associated with a New York City office, or an employment agency located in the city. Candidate notices go to people who live in New York City.

We found no headcount or funding-stage threshold in the law or the DCWP’s guidance, so a five-person startup is covered if it uses a covered tool for a New York City role.

What counts as an automated employment decision tool

The DCWP describes an AEDT as a computer-based tool that uses machine learning, statistical modeling, data analytics or artificial intelligence, and that substantially assists or replaces discretionary decision-making in employment. Examples include tools that score, rank or filter applicants, resume screeners, and automated assessments that produce scores or recommendations. The city’s guidance says “employment decision” covers screening at any point in hiring or promotion, not just the final choice. Scanning resume banks, conducting outreach and inviting people to apply are not covered.

A tool that only tracks candidates through stages, schedules interviews or posts jobs is not an AEDT by itself. It becomes one when it scores, ranks or screens candidates in a way that substantially assists or replaces human judgment. Features such as AI applicant scoring are the kind of feature to review under this law. If you are unsure about a tool, ask the vendor how it works and ask a lawyer.

What the law requires

1. A bias audit within the last year

An independent auditor must run a bias audit of the tool before you use it, and every year after. The audit calculates selection or scoring rates and impact ratios across sex, race and ethnicity categories and their intersections. Per the DCWP, the auditor cannot work for you or the vendor, and cannot have been involved in using, developing or distributing the tool or have a financial interest in either party. Categories that make up less than 2 percent of the data may be excluded.

The vendor may arrange the audit, but the city states that employers are ultimately responsible for making sure one was done. If you do not have enough historical data of your own, the audit can use data from other employers, and the DCWP says test data can be used when historical data is insufficient.

2. A published summary of the audit

You must make a summary of the most recent audit public, along with the date you began using the tool. The summary includes the audit date, the data source, the number of people whose category is unknown, and the counts, rates and impact ratios for every category. Post it in the employment section of your website or link to it with an active hyperlink.

3. Notices to candidates and employees

At least 10 business days before you use the tool on a New York City candidate or employee, you must tell them:

• that an AEDT will be used to assess them,
• the job qualifications and characteristics the tool will assess, and
• how to request an alternative selection process or a reasonable accommodation, where available.

You can give the notice in the job posting, by mail or by email. For applicants generally, a notice on your careers page works, and use can start 10 business days after it is posted. For promotion candidates, a written policy can be used.

4. A way for candidates to ask for an alternative or accommodation

The notice has to tell candidates how to ask. The law and rule, as we could verify them, do not themselves require you to offer an alternative selection process, but disability and discrimination laws may still require reasonable accommodations. Have a named contact, usually an email address, and a person who responds.

Penalties and enforcement

The law sets civil penalties per violation: up to $500 for a first violation and for each additional violation on the same day, then $500 to $1,500 for each later violation. Each day you use a tool in violation counts as a separate violation, and each notice you fail to give counts separately. The amounts are in the New York City Administrative Code and the DCWP’s penalty schedule. Discrimination claims are handled separately by the NYC Commission on Human Rights.

DCWP enforcement began on July 5, 2023, and relies largely on complaints. In December 2025 the New York State Comptroller audited that enforcement, reviewing the period from July 2023 to June 2025, and found it ineffective. The DCWP agreed to carry out most of the recommendations, including better complaint routing and more rigorous investigations (DLA Piper summary). We found no new DCWP rule or amendment to the law since then, so expect closer scrutiny of published audits and notices under the existing rules. Check the DCWP’s AEDT page for updates.

How other AI hiring laws compare

NYC’s bias audit model is one of several approaches, and the rest are still evolving. If you hire outside New York City, check these too. Most of the details below come from law-firm and government summaries, so confirm them.

What the federal executive order means

In December 2025, President Trump signed Executive Order 14365, which directs the Justice Department to challenge state AI laws, and the Attorney General set up the task force in January 2026. Law-firm summaries say the order does not itself void state or city laws, that obligations under laws like NYC’s remain in effect unless a court or Congress changes them, and that federal anti-discrimination law applies regardless (Fisher Phillips, Jones Walker). The practical advice is to keep complying with the rules that apply to you and to watch for developments, since this area is moving quickly.

What Dover’s careers page does

Dover’s ATS gives each company’s careers page a linked Equal Opportunity Employer page that states your commitment, explains that optional AI-assisted features do not make hiring decisions (your hiring team does, and you configure any AI prompts or models), and gives candidates a link to email you to request an accommodation or an alternative, non-automated process. You remain responsible for your own compliance, including any bias audit your use of a tool triggers. The product documentation has the details.

NYC Local Law 144 compliance checklist

1. List every tool that touches candidate screening: resume screeners, scoring or ranking features, assessments, interview analysis.
2. Decide for each whether it substantially assists or replaces your team’s judgment. When unsure, ask the vendor and a lawyer.
3. For each covered tool used on New York City roles, get the independent auditor’s summary and check that it is dated within the last year.
4. Publish the summary and the tool’s start date in the employment section of your website, or link to it.
5. Send candidate notices at least 10 business days before first use, with instructions to request an alternative or an accommodation.
6. Name an owner for those requests and set a response time.
7. Turn off or do not use the tool for New York City roles until the audit and notices are in place.
8. Calendar the annual renewal and keep records of audits, notices and requests.
9. Review the AI hiring rules for every other state where you hire.

When to check with legal counsel

Use this guide to get oriented, then confirm the details before you rely on them. Talk to an employment lawyer when:

• You are not sure whether a tool you use is an AEDT.
• You use AI to score, rank or screen candidates, or you analyze video or voice in interviews.
• You hire in New York City, Illinois, California, Colorado, Maryland or Texas, or across several states.
• You receive a complaint or a notice from a regulator.
• A new law, rule or court decision is announced. Effective dates and requirements are moving, and agencies publish guidance after laws take effect.

Reminder: this guide is general information, not legal advice. We verified it against the sources linked above in November 2026, but some details came from law-firm summaries, and the rules in this area keep changing. Always double-check with legal counsel before you rely on it.

A structured, human-led process is the strongest protection against bias complaints no matter which tools you use. See our guides on interview process best practices, how to interview inclusively and de-biasing job descriptions, and our guide to pay transparency laws for the other posting rules that apply when you hire in New York City.

Frequently asked questions

What is NYC Local Law 144?

It is New York City's law on automated employment decision tools, often called the AI hiring law. It requires an independent bias audit of covered tools each year, a public summary of the audit and advance notice to candidates, and the city's Department of Consumer and Worker Protection enforces it.

Does NYC Local Law 144 apply to my startup?

It applies to employers and employment agencies that use an automated employment decision tool to screen candidates or employees for jobs in New York City. We found no minimum company size or funding-stage exemption in the law or the city's guidance.

Does it apply to remote jobs?

It can. The city says the law covers jobs located at least partly in a New York City office and fully remote jobs associated with a New York City office. Check how your remote roles are tied to the city.

Is an ATS an automated employment decision tool?

Only if it uses machine learning, statistical modeling, data analytics or AI to substantially assist or replace discretionary decisions, such as scoring or ranking candidates. Tracking candidates, scheduling and posting jobs on their own are not the kind of tool the law targets, according to the city's guidance.

Can I rely on my vendor's bias audit?

The vendor can arrange an audit, but the city says employers are ultimately responsible for making sure one was done before they use the tool. Ask for the independent auditor's published summary and check its date, since an audit can be relied on for one year.

Did the 2025 federal AI executive order cancel state and city AI hiring laws?

No. Executive Order 14365 directs the Justice Department to challenge state AI laws, but law-firm summaries say it does not itself void them, and obligations under laws like NYC's remain in effect unless a court or Congress changes them. Keep complying and watch for developments.

Is this legal advice?

No. This is general information, last verified in November 2026. AI hiring rules are changing quickly, so always confirm how the law applies to your tools with an employment lawyer.