Who must comply with NYC Local Law 144?

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.

When do EU AI Act obligations apply to hiring systems?

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.

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.

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

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.

Can our AI vendor perform our bias audit?

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.

Research Library · Texas

Texas Companies Hiring Into the EU: What Actually Applies, and When

Summary: An Austin-headquartered company hiring for a role based in the EU, or operating an EU entity, is subject to the EU AI Act's high-risk obligations for recruitment AI, regardless of how light TRAIGA's own requirements are. That deadline was recently delayed from 2 August 2026 to 2 December 2027, which changes the near-term timeline without changing the underlying classification or the eventual obligation.

Why Texas law is not the relevant test here

TRAIGA governs AI use connected to Texas: conducting business in Texas, producing a product or service used by Texas residents, or developing or deploying an AI system in Texas. It has nothing to say about a Texas company's obligations when hiring for a role based in Frankfurt or Dublin. That question is answered by EU law, not Texas law, and the two operate on entirely independent tracks.

A Texas employer that has built a light TRAIGA-compliant governance program can still carry substantial, unaddressed EU AI Act exposure if it hires into the EU without separately scoping that obligation.

What actually triggers EU AI Act exposure

The EU AI Act's employment provisions apply based on where the AI system's output is used or where the employer is established, not based on where the employer's headquarters sits. A Texas company evaluating candidates for a role physically based in an EU member state, or operating a subsidiary entity within the EU, is within scope for that activity, even though the company itself is a Texas business with no other EU presence.

Recruitment, candidate selection, and evaluation tools sit within Annex III of the Act, which classifies them as high-risk. That classification triggers conformity assessment, technical documentation, human oversight, and post-market monitoring obligations that go well beyond anything TRAIGA requires.

The deadline actually moved

On 29 June 2026, the Council of the EU gave final approval to a 16-month delay for Annex III standalone high-risk systems, moving the compliance deadline from 2 August 2026 to 2 December 2027. This followed a Digital Omnibus proposal from the European Commission on 19 November 2025, driven by implementation being behind schedule, particularly around finalizing the technical standards needed for conformity assessment.

The delay is real and confirmed, not speculative. It changes when the full compliance machinery must be in place. It does not change the underlying classification of recruitment AI as high-risk, and it does not touch the Act's prohibited practices, which were never delayed.

What this means practically for an Austin employer with EU hiring

The extra runway is genuine, but it is not a reason to stop scoping the obligation. The sensible use of the additional time is:

Confirm whether you actually have EU exposure, by mapping which roles, entities, and candidate pools touch the EU, rather than assuming the question doesn't apply because the company is Texas-based.
Use the extended timeline for the structural work, conformity assessment processes and technical documentation, that benefits from not being built under deadline pressure.
Do not let TRAIGA compliance stand in for EU AI Act compliance. They are unrelated legal regimes with different tests, and satisfying one says nothing about the other.
Watch for outdated internal materials. Given how recently this delay was confirmed, it is common for planning documents, vendor contracts, and even legal guidance written earlier in 2026 to still reference the original August 2026 date.

Where this sits alongside your other obligations

An Austin company with genuinely national or global hiring is often managing several regimes simultaneously: TRAIGA's light intent-based standard at home, Local Law 144's audit and notice requirements for any New York City candidate, and now a longer but still real EU AI Act runway for any EU-connected role. None of these substitutes for another. The practical approach is treating each as its own scoping exercise rather than assuming compliance with the lightest regime, TRAIGA, covers the rest.

Frequently asked questions

Does TRAIGA compliance help at all with EU AI Act obligations? Not directly. They are separate legal frameworks with different tests and different regulators. Internal AI governance discipline built for one can inform the other operationally, but neither satisfies the other's legal requirements.

If we have no EU office, are we definitely out of scope? Not necessarily. Scope turns on where the AI system's output is used, which can include evaluating a candidate for an EU-based role even without an EU corporate entity.

Is December 2, 2027 a final date, or could it move again? It reflects final Council approval given on 29 June 2026. Barring further legislative amendment, this is the operative date, though the pace of EU AI Act implementation has already shifted once.

Does the delay mean we can deprioritize EU AI Act work entirely until 2027? The compliance deadline moved. The underlying classification did not. Using the extra time to build durable documentation is a better use of the runway than treating it as permission to ignore the obligation.

Are TRAIGA and the EU AI Act enforced by the same body? No. TRAIGA is enforced exclusively by the Texas Attorney General. The EU AI Act is enforced through EU member state authorities and, for certain matters, EU-level bodies. They share no enforcement mechanism.

PeopleNotResumes helps Austin employers scope their actual EU AI Act exposure rather than assuming Texas law is the whole picture. Our methodology is grounded in behavioural science research from the London School of Economics.