Am I covered by NYC Local Law 144? What counts as an AEDT
For US employers using AI in hiring, verified at source. About 4 minutes.
You are covered by New York City's Local Law 144 if four things are true at once: you are an employer or an employment agency, the role is tied to a New York City office, you use a tool to screen people who have applied, and that tool issues a score or ranking that substantially drives the decision. There is no minimum company size. If that describes you, three duties follow: an annual independent bias audit, a public summary of the results, and ten business days of notice to candidates.
What actually counts as an AEDT
The law turns on a defined term: an automated employment decision tool, or AEDT. The statute defines it as a computational process derived from machine learning, statistical modeling, data analytics, or artificial intelligence that issues a simplified output, such as a score, classification, or recommendation, used to substantially assist or replace discretionary decision making for employment decisions (NYC Administrative Code section 20-870, NYC DCWP, Local Law 144).
Two phrases carry the weight. A "simplified output" is a score, tag, recommendation, or ranking. And "substantially assist or replace" has a precise three-part test in the adopted rule (section 5-300): the output is relied on with no other factors considered, or it is weighted more than any other single criterion, or it is used to overrule conclusions a human reached on other grounds. If your tool's output does any one of those, it counts.
| Likely an AEDT | Not an AEDT |
|---|---|
| A resume screener that ranks or scores applicants. A tool that grades a video or assessment and advances the top results. Any model whose score drives, outweighs, or overrules the human call. | Tools that only translate or transcribe, such as converting a resume from PDF or transcribing an interview. And the explicit carve-outs in the statute: junk email filters, firewalls, antivirus, calculators, spreadsheets, and databases. |
Are you covered? Job location, who applied, and what the tool does
Coverage hinges on the job, not the candidate. The law reaches use "in the city," which DCWP reads as a role whose location is a New York City office at least part time, a fully remote role whose associated location is a New York City office, or an employment agency located in the city. The source does not define how to decide a remote role's "associated location," so that edge stays genuinely open; do not treat it as a bright line.
The notice duty works on a different axis: it is owed to candidates and employees who reside in New York City (section 20-871(b)). So the job location decides whether you are covered, and the candidate's residency decides who must be notified. Two nexuses, easy to conflate.
One more boundary. A "candidate" is someone who has applied for a specific position, and screening counts at any stage of hiring or promotion, not only the final decision. Sourcing and outreach to people who have not applied falls outside the law. The trigger is screening applicants, not finding them.
What being covered triggers
- An independent bias audit within the past year. Conducted by an independent auditor, no more than one year before use, and repeated annually for as long as you keep using the tool (section 5-301).
- A public summary of the results. Posted on the employment section of your website before use, with the audit date and the distribution date (section 5-303).
- Ten business days of notice. To New York City residents, before use, along with the qualifications the tool assesses and how to request the data on file (section 20-871(b)).
The exposure is real and cumulative. Penalties run up to 500 dollars on the first day, including additional violations the same day, and 500 to 1,500 dollars for each day after, with each day of non-compliant use treated as a separate violation, and each missing notice a separate violation again (section 20-872). The law has been enforced since 5 July 2023, so this is current, not a future project.
Size it for your own stack
Before you commission an audit or build a program, the first question is narrow: which of your tools are even AEDTs, and on which roles. That is free and takes a couple of minutes.
Take the free, two-minute self-assessment. A few questions tell you whether your hiring tool is likely in scope and what the first step is. No email needed to see your result.
Take the free 2-minute checkOnce you know you are covered, want the audit and notice steps as editable files your team fills in? See the Toolkit (US$ 99, one-time).
Next step once you are in scope: the NYC Local Law 144 bias-audit checklist. For the annual clock that catches teams off guard, read when a bias audit expires.
This is educational material and a starting point, not legal advice. New York City's Local Law 144 has its own rules and exceptions, and parts of the source material leave genuine edges open. For how it applies to your specific tools, roles, and locations, consult a qualified employment lawyer. Signato is not a law firm and does not certify compliance.
Every claim here is traced to the primary regulation and checked by a person before it goes out. We tell you what is settled, what is still open, and what to do next. How we work.