> Agent view (Markdown) of https://www.nycbiasaudit.com/blog/is-my-tool-an-aedt
> Publisher: Holistic AI (https://www.holisticai.com). Site index for agents: https://www.nycbiasaudit.com/llms.txt · Everything in one file: https://www.nycbiasaudit.com/llms-full.txt

# Is my hiring tool an AEDT? Four questions to find out

Published: 2026-10-21 · By Holistic AI

Not every hiring tool is an automated employment decision tool under NYC Local Law 144. Four plain questions, based on DCWP's rules, to work out whether yours is.

**In short:** A hiring tool is an automated employment decision tool when it uses data or AI to produce a score, rank or label, and that output carries real weight in a hiring or promotion decision in New York City. How you use the tool matters as much as what it does.

## Why this question comes first

Everything in Local Law 144 depends on it.

If your tool is an AEDT, you need a bias audit, a public summary and candidate notice. If it isn't, you don't.

The law leaves the first call to you. That's convenient, and it's also why so many employers have quietly decided they're out of scope.

Now that the city has committed to looking for problems itself, that decision deserves a proper answer.

## Question one: is it used for a hiring or promotion decision in NYC?

The law covers candidates for jobs and employees up for promotion, where the role is in New York City.

That includes remote roles tied to an NYC office.

If not, Local Law 144 probably doesn't apply. Other states may still have something to say.

## Question two: does it use machine learning, statistics or AI?

The city's definition is narrower than it sounds.

The tool has to make a prediction or a classification, like "likely to succeed" or "strong fit".

And a computer has to have at least partly decided which inputs matter and how much.

A keyword filter someone set up by hand might not qualify. A model trained on past hires almost certainly does.

## Question three: does it give you a simple output?

Think of a score, a ranking, a label or a recommendation.

A match score out of 100. A shortlist in ranked order. A "strong" or "weak" fit tag.

If the tool produces something like that, keep going.

## Question four: does that output really drive the decision?

This is where most of the judgment sits. The rules say the output substantially assists or replaces the decision if any of these is true.

You rely on it alone.

It counts for more than any other factor.

It can overrule other judgments, including a person's.

> **A QUICK TEST** Ask your recruiters how often they interview someone the tool ranked low. If the honest answer is "almost never", the score is doing the deciding.

## Typical examples

| Tool | Usually an AEDT? | Why |
|---|---|---|
| Resume screener with an automatic cut off | **Very likely** | The output replaces the decision |
| ATS match score recruiters sort by | **Often** | It tends to outweigh everything else |
| Scored assessment or game with a threshold | **Usually** | A score with a cut off |
| Video interview scoring | **Usually** | A score that carries heavy weight |
| Interview recording and transcription only | Usually not | No score or label |
| Scheduling chatbot | Usually not | No decision output |

How you use the tool decides the answer, so treat this as a starting point.

## Write it down either way

If you decide a tool is in scope, keep the audit, the published summary and your notices together.

If you decide it isn't, write down why, with the vendor's documentation, and set a date to look again.

Regulators have said they want to see how tools actually work, not just a signed statement.

Hiring across more than one state? Our 2027 playbook covers how the definition of an AI hiring tool differs from place to place. It's free in the sidebar.

*This article is general information, not legal advice.*

---

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.