Your NYC bias audit has an expiry date. When did yours pass?

Edition 16. A reading time of about 4 minutes.

The hook

A lot of companies hiring in New York City treat the bias audit as a thing they did once. They commissioned it, got a report, posted something, and moved on. The problem is that New York City's Local Law 144 does not work like a one-time clearance. The bias audit behind any automated hiring tool you use has to have been done by an independent auditor, and it has to be recent: no more than one year before you use the tool. So the real question is not "did we do a bias audit." It is "when did the one we are relying on expire." For a lot of teams, the honest answer is that they do not know, or that it lapsed quietly months ago while the tool kept screening candidates. This is not a future deadline. It has been enforced since 5 July 2023.

What this means

Local Law 144 is narrow and specific, which is exactly why it is easy to get wrong. It applies when you use an automated employment decision tool, an AEDT, on candidates or employees in New York City. The law defines that as a computational process, built from machine learning, statistical modeling, data analytics or AI, that produces a simplified output used to "substantially assist or replace discretionary decision making" in hiring or promotion (§ 5-300 of the NYC adopted rule; Epstein Becker Green). Resume screeners, scoring tools and ranking systems are the obvious cases. If a tool meaningfully drives who advances, assume it is in scope until you have confirmed otherwise.

When a tool is in scope, three things have to be true before you use it, and they are where the gaps usually sit.

First, the bias audit. It has to be done by an independent auditor, and it has to be current. The rule is explicit that the audit must be "conducted no more than one year prior to use" of the tool (NYC adopted rule § 5-301). That one-year window is the part teams forget. An audit from eighteen months ago is not a partial credit; for a tool you are still running, it is an expired requirement. The clock keeps moving even when the tool sits untouched.

Second, the summary of results. A summary of the most recent bias audit has to be published, publicly, on your website. Section 5-303 ("Published Results") of the adopted rule requires you to make the date of the most recent bias audit and a summary of its results publicly available on your site (NYC adopted rule § 5-303). Having the auditor's report sitting in someone's inbox is not the same as posting the summary where a candidate can find it. This is a publication duty, not a filing duty.

Third, the notice to candidates. People being evaluated have to be told. The notice has to go out at least ten business days before the tool is used on them (NYC Administrative Code § 20-871(b); adopted rule § 5-304). Ten business days, not ten calendar days, and ahead of use, not alongside it.

On consequences: this is enforced by the Department of Consumer and Worker Protection, and the penalty structure is built around continued use. A violation carries up to $500 for the first day, including any additional violation that same day, and between $500 and $1,500 for each subsequent violation, with each day the tool is used out of compliance counting as a separate violation (NYC Administrative Code § 20-872). The structure matters more than the numbers. Because each day is its own violation, a lapsed audit or a missing summary is not a single mistake. It is a meter running for as long as the tool keeps going.

One honest caveat. What counts as an AEDT, and what a compliant summary needs to contain, are the areas where reasonable advisers still disagree at the edges, and the definition has been read narrowly by some employers. That is a question for a lawyer who knows your specific tools. The three obligations themselves, audit within a year, summary published, ten business days notice, are settled and live.

What to do with this

You do not need a lawyer to find out where you stand. The first moves are about knowing what you run and getting the dates in writing.

1. Find the expiry date on every tool you use in NYC. List each AEDT that touches NYC candidates, then pull the date of the bias audit you are relying on for each one. If that date is more than one year ago, or you cannot find it, you have your answer: that tool is running on an expired or unknown audit right now. Confirm the auditor was independent while you are at it.
2. Check that the summary is actually published, not just produced. Go to your own careers site as a candidate would and look for the summary of results. If it is not posted publicly, the audit existing somewhere does not satisfy the duty. Get the live URL on the record.
3. Get the notice on the record, ten business days out. Confirm that candidates are told before the tool is used, with at least ten business days of lead time, and keep the proof, the notice text, the dates, the send record. So when someone asks, you have the answer ready instead of a scramble.

Read this way, Local Law 144 is less about a one-off audit and more about keeping three pieces of evidence current: an independent audit dated within the last year, a summary published where candidates can see it, and a record that the notice went out in time. The teams that sleep well are not the ones who audited once. They are the ones who know exactly when each piece expires.

This is educational material and a starting point, not legal advice. US AI hiring rules are a patchwork that varies by state and city, and they change over time. Whether a given tool is an AEDT, and what a compliant bias audit and summary require, depend on the specific facts. For how New York City's Local Law 144, or any other state or local rule, applies to your tools and locations, consult a qualified lawyer in each jurisdiction. Signato is not a law firm and does not certify compliance.

Not sure where your NYC hiring tools stand? Take the free AI Hiring Risk Self-Assessment to see where you are exposed, then see the same evidence-first discipline applied to what your AI sends out: the free local trial of the Signato chamber blocks a draft that pairs the wrong person with the wrong subject before it leaves, no card, nothing leaves your machine. The trial does not replace the independent bias audit Local Law 144 requires, that has to come from a separate, independent auditor.

Every claim here is traced to the law and its official rules, and checked by a person before it goes out. We tell you what is settled, what is still debated, and what to do next. Know someone who uses AI to hire in New York? Forward this to them.

Sources (primary, read 2026-06-15):

- NYC DCWP, "Automated Employment Decision Tools (AEDT)", the enforcing agency's official program page for Local Law 144 and the AEDT rules. This is the program of record for the bias audit, published summary of results, and candidate notice obligations. - NYC adopted Final Rule, "Automated Employment Decision Tools" (6 RCNY §§ 5-300 to 5-304), the adopted rule text (status "Adopted", effective 5 July 2023): the bias audit must be "conducted no more than one year prior to use" of the AEDT (§ 5-301); § 5-303 "Published Results" governs the summary that must be published on the website; § 5-304 sets the candidate notice at least 10 business days before use; the AEDT definition turns on tools that "substantially assist" discretionary decision making in employment (§ 5-300). The "-2" slug on the same site is the 2022 proposed rule, where these sections were numbered differently. - NYC Administrative Code, Title 20, Chapter 5 (Local Law 144 as codified), § 20-871(b) requires candidate notice at least 10 business days before use; § 20-872 sets the penalties (up to $500 for a first violation and any additional violation the same day; $500 to $1,500 for each subsequent violation; each day of non-compliant use is a separate violation). The amlegal domain returns 403 to automated fetch; the Code text is reproduced verbatim in the legal sources read 2026-06-15. - IAPP, "Practical considerations for bias audits under NYC Local Law 144", supports: the bias audit must be by an independent third party; "a 'summary' of the bias audit results must be published on the employer's or employment agency's website"; "notice ten business days before using the AEDT"; enforcement "since July 5, 2023"; and the per-violation, per-day penalty structure ($500 on the first day, then $500 to $1,500 per subsequent violation, each day of non-compliant use a separate violation). - Epstein Becker Green, "Taking Stock of New York City's Automated Employment Decision Tools Law", corroborates the AEDT definition ("substantially assist or replace discretionary decision making"), the independent annual bias audit, the published summary, the ten business days notice, the July 5, 2023 enforcement start, and the per-day penalty structure.