NYC LL 144 Enforcement: First Fines Issued — What Happened and What It Means

New York City's Department of Consumer and Worker Protection (DCWP) has begun enforcement of Local Law 144, issuing the first fines to employers who failed to conduct required bias audits of their AI hiring tools.

What the Enforcement Actions Covered

The initial enforcement actions targeted employers who:

1. Used AI hiring tools without conducting a bias audit — The law requires an annual third-party bias audit of any automated employment decision tool (AEDT) used for NYC-based hiring or promotion decisions.
1. Failed to post bias audit results — Results must be publicly available on the employer's website or in the job posting, before the AEDT is used.
1. Did not provide required candidate notices — Employers must notify candidates that an AEDT is being used in their application process, along with what it evaluates.

What the Fines Were

NYC LL 144 provides for fines of up to $1,500 per violation per day for willful violations. Initial fines were in the range of $500–$1,500 per violation, with penalties accumulating for each day the violation continued.

The Three Common Mistakes

Mistake 1: Assuming the vendor's compliance covers you

Many employers believed that because their ATS or recruiting software vendor had conducted a bias audit, they were covered. They are not. The deployer — the employer — is responsible for compliance, not the vendor. You need a separate bias audit of the AEDT as it is used in your hiring process.

Mistake 2: Not knowing what counts as an AEDT

An AEDT is any computational process that uses machine learning, statistical modeling, data analytics, or AI to assist or replace discretionary decision-making in employment. This includes:

• Resume screening AI
• Video interview analysis tools
• Candidate scoring and ranking systems
• Skills assessment AI

Mistake 3: Buried or inaccessible audit results

The law requires audit results to be "publicly available" — not buried in a PDF on an obscure careers page sub-page. Results must be easy to find and include the required data fields.

What You Need to Fix Now

1. Identify all AEDTs you use for NYC candidates or employees
2. Commission a bias audit from a qualified third-party auditor
3. Post audit results prominently on your careers page or in job postings
4. Add candidate notices to all job applications for NYC roles
5. Set a recurring reminder — audits must be repeated annually

Resources

• Full NYC LL 144 compliance guide
• Find a bias audit firm
• Check if LL 144 applies to you