5 Signs Your Hiring Tools Might Put You on the Wrong Side of Local Law 144
Most companies that fall out of compliance with NYC Local Law 144 do not do it on purpose. They do it because a tool they already use quietly crossed a line they did not know was there. The law does not care whether the software is branded as AI or whether a recruiter signs off at the end. It cares whether a tool is scoring, ranking, or recommending candidates for a New York City job.
Here are five signs your stack may already be in scope. If any of them sound familiar, it is worth a closer look.
1. Your software gives candidates a score or a match percentage.
If a tool assigns applicants a number, a grade, or a fit percentage, that is a simplified output, which is exactly what the law regulates. It does not matter if a human makes the final call. If your team relies on that score to decide who advances, the tool is substantially assisting the decision.
2. Your applicant tracking system ranks or shortlists for you.
A plain system of record that just stores applications is usually fine. But many modern platforms now bundle a matching or ranking feature that surfaces the "top" candidates. That feature can pull an otherwise neutral system into scope, even if you never turned it on deliberately. Worth checking what your ATS is doing under the hood. Our guide on what counts as an automated employment decision tool walks through this.
3. A team adopted a tool without telling anyone.
Shadow tools are one of the most common sources of hidden risk. A recruiter signs up for a sourcing tool with a free trial, likes it, and keeps using it. Nobody classified it, nobody audited it, and it is quietly scoring candidates for New York City roles. If you have not done a full inventory recently, you probably have at least one.
4. You use AI to screen video interviews or chat responses.
Tools that evaluate how a candidate answers, whether by scoring video responses or gating applicants through a screening chatbot, are producing exactly the kind of output the law targets. These often feel like efficiency features rather than decision tools, which is precisely why they get missed.
5. You have never published a bias audit or notified candidates.
This is the clearest sign of all. If you are using any of the tools above for New York City roles and you have not published an audit summary or sent candidate notices, you are almost certainly not compliant yet. The law requires an independent bias audit within the prior year, a published summary, and at least 10 business days' notice to candidates before use.
The good news
None of this means you did something wrong, and none of it is hard to fix once you can see it. The hardest part is usually just knowing which tools are in scope, and that starts with a simple inventory. If you want a clear picture of where you stand, a Compliance Score will map your stack and tell you exactly what needs an audit and what does not.
Not sure whether your tools are covered? Start with the complete guide to NYC Local Law 144, or reach out and we will take a look with you.