Question 1

Who must comply with NYC Local Law 144?

Accepted Answer

Any employer or employment agency using an automated employment decision tool (AEDT) to screen candidates for a job located in New York City, regardless of where the employer is headquartered. They must run an independent bias audit within the prior year, publish the summary, and notify candidates at least 10 business days in advance.

Question 2

When do EU AI Act obligations apply to hiring systems?

Accepted Answer

AI systems used for recruitment and employee selection are high-risk under Annex III 4(a). High-risk obligations for hiring systems apply from December 2, 2027, delayed from the original August 2026 date under the EU's Digital Omnibus on AI, approved by the Council on 29 June 2026, covering risk management, data governance, human oversight, transparency, logging, and post-market monitoring.

Question 3

What is an AEDT?

Accepted Answer

An Automated Employment Decision Tool is any computational process derived from machine learning, statistics, or AI that produces a score, classification, or recommendation used to substantially assist or replace discretionary hiring or promotion decisions.

Question 4

What are the penalties for NYC Local Law 144 non-compliance?

Accepted Answer

Fines start at $500 for a first violation and reach $1,500 for each subsequent violation. Each day of non-compliant use and each missed candidate notice counts as a separate violation.

Question 5

Can our AI vendor perform our bias audit?

Accepted Answer

No. NYC Local Law 144 requires an independent auditor with no role in building, selling, or using the tool and no financial interest in it. Vendors can supply data but cannot serve as the independent auditor.