NYC Local Law 144 checklist: AI hiring tools, bias audits and candidate notice (2026)
Checklist
- List every tool that produces a score, rank, classification or recommendation about candidates.
- For each: is it used for NYC roles? Who is the employer of record?
- Independent bias audit within the last 12 months (selection or scoring rates and impact ratios by sex, race/ethnicity and intersections).
- Public summary on the careers site: audit date, data source, counts, impact ratios, tool distribution date. Keep it up at least 6 months after last use.
- Candidate notice in advance of use (the DCWP rules set the notice requirements).
- Vendors: publish your own audit so customers can link to it; it does not move their duty, but it removes friction in every deal.
What happens if you skip it
The DCWP FAQ penalty schedule runs from $375 to $1,500 per violation (Gibson Dunn summary). A New York State Comptroller audit published in 2026 found DCWP enforcement had gaps and reviewed public company websites for compliance, so public pages are what gets checked.
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