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# What New York's audit of Local Law 144 means for employers

Published: 2026-10-21 · By Holistic AI

The New York State Comptroller says enforcement of NYC's AI hiring law has been ineffective. Here's what that means for employers using automated employment decision tools, and what to check first.

**In short:** The state looked at how New York City enforces its AI hiring law and didn't like what it found. The city has agreed to change course. If you use an automated employment decision tool to screen candidates in NYC, your public bias audit is about to get read more closely.

## A quick reminder of what the law asks

Local Law 144 has been enforced since July 2023.

If you use an automated employment decision tool (an AEDT) to screen candidates or employees for promotion in New York City, you need three things.

An independent bias audit, done within the last year.

A public summary of the results on your website.

Notice to candidates at least 10 business days before the tool is used.

That's it. Simple on paper. In practice, plenty of employers never did it.

## So what did the state find?

In December 2025 the New York State Comptroller published an audit of the NYC Department of Consumer and Worker Protection (DCWP), the agency that enforces the law.

The headline was blunt. Enforcement had been "ineffective".

- **2**: AEDT complaints DCWP received in two years
- **3 of 12**: test calls to 311 that reached DCWP
- **1 vs 17**: potential issues found by the city vs. state auditors

A few details stand out.

In two years, DCWP received only two complaints about AI hiring tools.

That sounds like good news until you learn why. When the auditors called 311 to report a problem, most of their calls never reached DCWP at all.

Then there was the review of published bias audits. DCWP looked at a group of employers and found one potential problem. The state's auditors looked at the same audits and found 17.

## The three mistakes worth knowing about

You don't need the whole report to take something useful from it. The problems the auditors found fall into three groups.

| Mistake | What it looks like | How to check yours |
|---|---|---|
| Not independent | The vendor ran the testing and someone else wrote it up | Ask in writing who ran the numbers |
| Incomplete math | Candidates grouped into tiers instead of compared group by group | Look for a ratio for every group, including combined ones |
| Unexplained data | No clear source or explanation for the data | Check that the summary names its data and why it was used |

None of these are exotic. They're the kind of shortcuts that happen when an audit is treated as paperwork.

## What changes now

DCWP pushed back on parts of the report. It still agreed to adopt many of the recommendations.

The ones that matter most to you are simple.

The city will look for problems itself instead of waiting for complaints.

It will keep track of whether audits are kept up to date.

It will use the technical checklist the city's own technology office built for reviewing audits.

In other words, enforcement starts with what anyone can see. Your published summary. Your audit date. Your candidate notice.

## Where to start this week

Pull up your published audit summary and read it as a stranger would.

- [ ] The auditor is clearly independent of you and of your vendor
- [ ] Results cover every group, including combined sex and race/ethnicity categories
- [ ] The data source is explained
- [ ] The audit date is less than a year old
- [ ] The summary is easy to find from your careers page

If any answer is "not sure", that's your starting point.

Our research report walks through every finding in detail, with a 12 point checklist mapped to each one. You can download it free from the sidebar.

*This article is general information, not legal advice. Source: New York State Comptroller audit report, December 2025.*

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Holistic AI carries out independent Local Law 144 bias audits. What the service includes: https://www.nycbiasaudit.com/services.md. To commission a bias audit or ask a question, book a call at https://www.nycbiasaudit.com/demo or email we@holisticai.com.