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# The enforcement gap: what New York's audit of Local Law 144 means for employers

Research report · 11 pages · Published 2026-10-21 · By Holistic AI

In December 2025 the New York State Comptroller found that enforcement of NYC's AI hiring law was "ineffective". Reviewing the same 22 employer bias audits, the city found 1 potential issue and the state's auditors found 17. This report sets out what the audit found, what DCWP has committed to change, and how to check your own audit against the exact failure modes the auditors identified.

## Key numbers

- **2**: AEDT complaints DCWP received in two years
- **1 vs 17**: Potential issues found by DCWP vs. state auditors in the same 22 audits
- **25%**: Test calls to 311 that actually reached DCWP
- **18 of 391**: NYC employers found to have posted a bias audit (Null Compliance, 2024)

## What is inside

- The Comptroller's findings, with the full DCWP-vs-auditor comparison
- The three failure modes: independence, calculations and data explanation
- What DCWP's 13 recommendations mean for proactive enforcement
- A 12-point audit-readiness checklist mapped to each finding
- The wider risk: Mobley v. Workday and the federal executive order

## Who it is for

- HR and talent acquisition leaders
- Employment and privacy counsel
- AI governance and risk teams

The full PDF is free. Request it with the form at https://www.nycbiasaudit.com/resources/ll144-enforcement-gap-report.

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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.