AI as a safety component of regulated medical devices falls under Annex I; standalone clinical decision AI can be Annex III high-risk. High-risk duties apply from December 2, 2027 (Annex III) and August 2, 2028 (Annex I embedded).
NYC LL 144 covers employment decisions only, not clinical AI. Healthcare employers using AEDTs for NYC-located jobs are covered on the hiring side.
Health care is a covered consequential-decision domain, but HIPAA covered entities and business associates are carved out of the core duties. Check your entity status before assuming coverage either way.
Illinois AIVIRA covers AI analysis of employment video interviews only. Clinical AI is not covered.
Annex III lists AI for recruitment, selection, screening, promotion, and termination as high-risk. Conformity assessment duties apply from December 2, 2027.
The core use case. Any AEDT used for hiring or promotion for jobs located in NYC needs an annual independent bias audit (including intersectional categories), public posting of results, and 10-day advance notice.
Employment decisions made or materially influenced by ADMT for Colorado consumers are covered. Pre-use notice, adverse-decision explanation, and human-review rights apply from January 1, 2027.
Illinois AIVIRA covers AI analysis of video interviews: notice, explanation, written consent, 30-day deletion on request, and annual demographic reporting where AI screens in-person interview eligibility.
Annex III includes AI for creditworthiness assessment and credit scoring as high-risk (from December 2, 2027). GDPR Article 22 profiling rules apply separately.
NYC LL 144 covers employment decisions only; lending AI is out of scope. Federal ECOA and FCRA obligations apply separately.
Financial and lending services are a covered domain. ADMT that makes or materially influences credit decisions for Colorado consumers triggers notice, explanation, and human-review duties from January 1, 2027.
Illinois AIVIRA covers employment video interviews only; lending and credit AI are out of scope.
Annex III includes AI for risk assessment and pricing in life and health insurance as high-risk (from December 2, 2027).
NYC LL 144 covers employment decisions only; underwriting AI is not covered unless used for hiring.
Insurance is a covered domain, but insurers subject to C.R.S. 10-3-1104.9 (and affiliates) are deemed compliant in the practice of insurance. Verify whether the carve-out reaches your use case.
Illinois AIVIRA covers video interview AI only. The Illinois Department of Insurance has separate guidance on AI underwriting.