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ComplianceSelf-AssessmentNYC Local Law 144EU AI Act

The 15-Minute AI Hiring Compliance Gut Check

PeopleNotResumes··4 min read

You do not have time for a compliance project this week. Fair enough. But you probably do have 15 minutes, and 15 minutes is enough to find out whether you are in reasonable shape or quietly carrying risk. Think of this as a quick self-diagnostic, not a substitute for a real audit, but a fast way to know how worried to be.

Run through these seven questions honestly. Keep a tally of your yes answers.

1. Do you know every tool in your hiring stack?
Not roughly. Actually. Including anything individual recruiters or teams signed up for on their own. If you cannot list them all from memory or a maintained inventory, that is your first gap.

2. Do any of those tools score, rank, or recommend candidates?
If yes, at least one of them is likely an automated employment decision tool, which is what the laws regulate. A tool that just stores applications is fine. A tool that produces a shortlist or a fit score is not the same thing.

3. Do you hire for roles in New York City, or anyone in the EU?
Location is the trigger. A New York City job pulls in Local Law 144. An EU-based role pulls in the EU AI Act. Remote roles tied to those locations often count too.

4. Has each in-scope tool had an independent bias audit in the last 12 months?
"Independent" is the key word. If the audit came from the vendor, it does not count, because the vendor is disqualified from being your independent auditor.

5. Have you published an audit summary where candidates can find it?
Local Law 144 requires it, along with the tool's first-use date, somewhere reachable, not buried in a legal footer.

6. Do candidates get notice before a tool is used on them?
At least 10 business days for New York City roles, explaining that a tool will be used and how to request an alternative. Bonus points if the notice fires automatically rather than depending on someone to remember.

7. Is one specific person responsible for keeping all of this current?
Audits expire yearly, new tools appear, and laws change. If the answer to "who owns this" is "no one in particular," you will drift out of compliance even if you are fine today.

How to read your score

If you answered yes to all seven, you are in strong shape. Keep the monitoring going. If you answered yes to most but stumbled on one or two, you have a targeted gap to close, not a crisis. If you answered no to several, do not panic, but do treat it as a signal to look properly. The compounding, per-day nature of the penalties means small gaps get expensive the longer they sit.

The reassuring part is that closing these gaps is a matter of weeks, not months, once you can see them clearly. The AI hiring compliance checklist lays out the full sequence.

If your gut check turned up more red than green, a Compliance Score will turn those unknowns into a clear, prioritized list of what to fix first. That is the whole point of it: less worry, more clarity.