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# Local Law 144 penalties in 2026: what's changed and what hasn't

Published: 2026-10-21 · By Holistic AI

NYC's AI hiring law hasn't changed in 2026, but enforcement has. Here's how Local Law 144 penalties work, why they add up quickly, and where employers are most exposed.

**In short:** The rules are the same as they were in 2023. The penalties are the same too. What's different is that the city has promised to go looking for problems, which makes small gaps a lot more visible.

## The penalties, in plain terms

The NYC Department of Consumer and Worker Protection (DCWP) can fine you between $500 and $1,500 per violation.

On its own, that doesn't sound like much.

- **$500**: first violation
- **$500 to $1,500**: each violation after that
- **10 days**: of notice candidates must get, counted in business days
- **12 months**: how long an audit stays valid

The catch is how violations are counted. Every day you use an automated employment decision tool without a valid bias audit can count as a separate violation. So can each missed candidate notice.

A few months of quiet noncompliance turns into a real number fast.

## What hasn't changed

The law itself.

You still need an independent bias audit every year, a public summary of the results, and notice to candidates at least 10 business days before the tool is used.

No amendment has passed. No new rule has been issued.

| | When enforcement began (2023) | Now (2026) |
|---|---|---|
| The law and its rules | In force | Unchanged |
| Penalties | $500 to $1,500 per violation | Unchanged |
| How problems are found | Mostly complaints | The city has agreed to look proactively |
| Expired audits | Not tracked | The city has agreed to monitor them |

## What has changed

### The state put enforcement on the record

In December 2025 the New York State Comptroller reviewed how DCWP had enforced the law and called it ineffective.

Complaints weren't reaching the agency. Reviews of published audits were missing problems. There was no system to check whether audits had expired.

### The city agreed to do more

DCWP has agreed to adopt many of the Comptroller's recommendations.

The important shift is this: the agency will look for noncompliance on its own instead of waiting for someone to complain.

### The wider risk grew too

Courts are taking AI hiring discrimination claims seriously. Other states have passed their own AI hiring laws. A bias audit is no longer just a city requirement. It's evidence.

## Where you're most exposed

Proactive enforcement starts with what's public. If someone outside your company looked today, what would they see?

- A tool you use but no published audit
- An audit summary that's more than a year old
- An audit where the vendor did the testing
- Results that don't cover every group the rules require
- A summary that doesn't explain its data

Each of these can be spotted from your website in a few minutes.

## A five minute check

Open your careers page.

- [ ] The bias audit summary is one or two clicks from your careers page
- [ ] It's dated within the last 12 months
- [ ] It names an auditor independent of you and of your vendor
- [ ] Candidate notice goes out at least 10 business days before the tool is used

If you hesitated on any of those, it's worth a closer look now rather than later.

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

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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.