NYC LOCAL LAW 144 · BIAS AUDIT · ANNUAL

Your vendor’s bias audit probably doesn’t cover you.

Local Law 144 binds the employer, not the vendor - an independent bias audit, a published summary, and candidate notice, every year.

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A compliance professional seated at a desk in a warm, low-lit office, signing a printed document with a pen, further papers and a cup of coffee on the desk beside them and a window throwing daylight across the page.
Independent means no stake in the answer
AEDT Selection rate Impact ratio EEO-1 categories Candidate notice

Our promise

“A summary is a claim. The audit is evidence.”

Every finding is written against a clause of the instrument itself — defensible line by line, to anyone who asks. The fee is fixed at $6,500, and nothing is charged until you approve it.

Each additional tool
$1,500
Re-audit, same scope
$4,200
Renewal, every twelve months
$5,500 locked

This costs more than the estate ladder, and it should. The ladder is a private assessment written for you. A framework audit produces a published summary iDharma maintains for twelve months - a notice template where the law requires one, a 60-day expiry warning, and a quarterly check that the summary is still live and still linked.

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The case file

Local Law 144, in three chapters

The Law

New York City began enforcing Local Law 144 on July 5, 2023 - the first law in the United States to require a bias audit of the automated tools employers use to hire and promote. If a tool substantially assists those decisions for a job in the city, the audit is not optional, and it must be independent.

The Gap

Most employers assume their vendor’s published audit covers them. Usually it does not: you may rely on it only if your own historical data went into it. Add the rolling twelve-month clock and the ten-business-day notice, and quiet non-compliance is the default state of an ATS.

The Office

We are the independent auditor the law asks for. iDharma runs the audit on your own applicant data, reporting selection rates and impact ratios by sex and race/ethnicity with intersectional categories included, and hands you the published summary, formatted and ready to post.

What is an AEDT?

A tool that decides before you do.

A tool that ranks or screens candidates and substantially assists the hiring decision.

Who owes this audit № 01
  • Employers hiring for NYC-based roles
  • Employment agencies screening for New York clients
  • Teams whose ATS scores, ranks, or filters applicants
  • Anyone using an automated tool in promotion decisions
LL144 · iDharma · Presented for assay
When the duty triggers № 02
  • The tool substantially assists a hiring or promotion decision
  • Before first use - candidates get ten business days’ notice
  • Every rolling twelve months the tool stays in use
  • Whenever the audited model is retrained or replaced
LL144 · iDharma · Presented for assay
Whose duty is it

The duty is yours. The tool is theirs.

You

The employer or agency

Local Law 144 places the obligation on whoever uses the tool to make the employment decision. Commissioning the audit, publishing the summary and its distribution date, and notifying candidates are all yours. None of them can be discharged by somebody else.

Your vendor

The people who built the tool

Carries no obligation of its own under this law. Many vendors commission a bias audit anyway and publish the results, and those audits are often genuinely good work. The difficulty is not their quality - it is whose applicants they were run on, and those were never the people that you screened.

The catch

When you can lean on their audit

You may rely on a bias audit conducted using other employers' historical data only if you contributed your own historical data to it, or you have never used the tool. If you have been running it on your own applicants and your own data was not in that audit, then it does not cover you and never did.

What most teams assume

“Our vendor published a bias audit, so we’re covered.”

What the rule says

If your data was not in it, you have no audit.

It is the most common finding we write up.

  • Who it is for
  • HR-tech vendors
  • Staffing & recruitment
  • In-house talent teams
  • Legal & compliance
  • ATS and assessment platforms
Why this matters in 2026
A black archive binder closed on a dark desk under a low lamp, a blank brass label plate screwed to its spine and a wax seal holding the page block shut, with a clipped sheet of bar-charted results, reading glasses, a fountain pen and a photograph of a brass stamp laid out beside it: the record of a tool's use, sealed after the fact.
01 Penalties run per violation, per day - $500 for the first, $1,500 for each one after. A season of quiet non-compliance is not one fine. It is arithmetic.
02

Each day an unaudited tool is used is a separate violation - and a missed candidate notice is counted separately again, per candidate.

03

The audit ages out on a rolling twelve months, against the day of use. An audit from last year covers nothing you are doing today.

04

Your published summary is checkable from the outside. Enforcement can begin from nothing more than your own careers page.

The 60-second check

Three questions. Then you’ll know.

No email. No signup. A starting point, not a determination.

0 of 3

Roles in New York City -

The job, not the head office. A company registered anywhere owes this audit for a role posted in the five boroughs - and a remote role advertised to New York candidates counts as located there.

Tool assists the decision -

Suppression counts. A tool that quietly deprioritises a candidate is assisting the decision, even where no rejection was ever recorded.

Audit on your own data -

Vendor audits rarely transfer. You may rely on one only if your own historical data went into it, or you have never run the tool.

The calendar

Four moments, and not in the order you’d guess.

Each of these is a deadline measured against the day the tool is used - so they cannot be added up, and they cannot be run in parallel.

  1. Audit

    Under 12 months

    The audit is a rolling twelve months against the day the tool is used - a live date, not your financial year end.

  2. Publish

    Before use

    Summary of results and the tool's distribution date, on your careers page - not behind a login or on request.

  3. Notify

    10+ business days

    Business days, not calendar days - roughly two weeks once holidays land in it. The most commonly missed.

  4. Re-audit

    Annually

    The clock runs from the audit date, not your financial year. Let it lapse and every day of use is a fresh violation.

The trap

Teams schedule the audit and forget that the notice period sits in front of first use. If you plan to go live on the 1st, the notice went out around the middle of the month before - and the audit was already done and published by then.

Requirement & coverage

What the rule says, what we ship

12 obligations, and the artefact that discharges each one. Paired, so every claim on this page can be checked against the requirement beside it.

Whose obligation it is Employer or employment agency - never the vendor
A written determination of who owes the duty for each tool, so a vendor's audit is never mistaken for yours.
Reliance on another audit Only if you contributed your data, or never used the tool
An assessment of whether you may lawfully rely on your vendor's audit - and what must be re-run if not.
Annual bias audit By an independent auditor, no more than one year before use
A dated audit by an auditor with no role in building, selling or operating the tool.
Selection rate For each category the rule names
Selection rate for every sex and race/ethnicity category, and scoring rate where the tool scores.
Impact ratio Each category against the most-selected category
Impact ratio for each category, computed the way the rule defines it.
EEO-1 Component 1 categories The category set is not ours to choose
Categories taken from EEO-1 Component 1, so the output matches what a regulator expects.
Intersectional categories Every combination of sex and race/ethnicity
The full intersectional grid - where disparities invisible on either axis alone appear.
Small-category handling Categories under 2% of the data may be excluded
Exclusions applied only where the rule allows, with the count and percentage shown.
Unknown-category count People assessed but not classifiable
Unknown-category counts stated separately, so the denominator is never quietly reduced.
Data source and method Where the numbers came from
Data source, type, number assessed and the audit date - the record behind the figures.
Published summary On the employment section of your site
A publication-ready summary and distribution date, formatted to drop onto your careers page.
Candidate notice At least ten business days before use
Notice templates covering use, qualifications assessed, the alternative-process route, and data retention.
The engagement

HR-tech AI, independently audited

From CV screening to conversational agents.

  1. Intake

    Which tools are in scope, and the data the calculations run on.

  2. Test

    Selection or scoring rate and impact ratio, intersections included.

  3. Sign off and publish

    You see the draft first. Then the report, summary and notices - dated.

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The numbers are not negotiable - that is what you are buying.
Struck in your favour

Why employers choose iDharma as their LL 144 auditor

Genuinely independent

We build, resell and operate no hiring tools, and we take no fee tied to what the audit finds.

Written to the rule

Every figure maps to the requirement it discharges, so a reviewer checks it against the law itself.

One engagement, end to end

Inventory, audit, summary and notices sit in one scope, so no publication date slips between vendors.

Intersectional by default

The full sex-by-race grid is in the base scope, not an upsell - it is where the findings turn up.

Four marks, struck on every report.

Deliverables

What you get

Concrete artefacts, each with a name and a format - you know what lands before you buy.

Bias audit report

The full audit: method, data sources, every selection rate and impact ratio, and the findings written in plain language - selection or scoring rate for every EEO-1 sex and race/ethnicity category and intersection, each impact ratio against the most-selected group, and the reason for any exclusion, signed by an independent auditor.

Workbook

Statistical results

The underlying tables in a workbook, so your own analysts can reproduce every figure in the report, cell by cell, without asking us for it.

HTML + PDF

Publication-ready summary

The summary of results and the distribution date, marked up ready to paste into the employment section of your site - as HTML and PDF.

Templates

Candidate notice pack

Notices covering the tool’s use and the qualifications assessed, the route to an alternative process, and the ten business days’ timing.

Memo

AEDT scope memo

Which tools were in scope, which were not, and why each call was made - the written record that stands behind your AEDT inventory.

Ranked

Remediation shortlist

Where the ratios point to a problem, what to look at first, and why. Findings ranked by consequence to candidates, not by ease of fixing.

Memo

Vendor-audit assessment

Whether your vendor’s published bias audit covers you under the data-contribution test - and what exactly must be re-run if it does not.

Format & fee

Real numbers, upfront.

Scope
Set by the instrument, not by us
Data
Your historical applicant data
Re-assay
Every rolling twelve months - $5,500 against your known baseline

The law fixed the scope, so the fee is flat - nothing to meter, and nothing charged until you approve the scope.

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LL144 · Named engagement $6,500 flat
  • Independent bias audit report
  • Impact ratios by sex & race/ethnicity
  • Published-summary text, ready to post
  • Candidate-notice language included
Show your hand

Four things you have to be able to produce

Local Law 144 is not graded on intent. Each of these is either in your hand on the day someone asks, or it is not.

The audit,
dated

An independent bias audit no more than one year old, run by someone with no stake at all in the tool. There is no grace period: a lapsed audit is, for compliance, no audit.

The summary,
published

The results summary on your own site, carrying the distribution date and reachable without a login. Running the audit and publishing it are two separate duties in law.

The notice,
in time

At least ten business days' notice to candidates that a tool will be used, what it measures and what it takes in - and given before it is used on them, not afterwards.

The numbers,
by group

Selection or scoring rates and the impact ratios between groups, by sex and by race/ethnicity, and by the two intersected. The table is the evidence, not assurance.

Four cards, and the date on each one is part of the card.

FAQ

Plain answers

Scope, timing, what gets published, penalties. Answered straight.

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Our ATS vendor already published a bias audit. Are we covered?

Probably not - this is the most common misreading of the law. You may rely on a vendor's audit only if your own historical data was in it, or you have never used the tool.

What counts as an AEDT?

A computational process producing a score, classification or ranking that substantially assists or replaces a discretionary employment decision. The test is what the output does to the decision, not what the vendor calls the product.

How long does an audit take?

Typically two to four weeks from data hand-over for a single tool, longer where the inventory turns out to be bigger than expected - which it usually does. Scope is agreed with you before anything is charged.

What do we actually have to publish?

A summary of the audit results and the tool's distribution date, on the employment section of your website - publicly available, not behind a login and not on request. You get it formatted and ready to paste.

What are the penalties?

$500 for a first violation and for each additional violation on the same day, then $500 to $1,500 for each subsequent one. Every day a non-compliant tool runs is a separate violation, and a missing notice is its own.

Get started

Request your bias audit

Tell us about your AEDTs and we come back with a scoping call within one business day.

What we need from you

Nothing you do not already have. Most of this comes out of your ATS and your vendor’s paperwork in an afternoon, and we tell you which extracts before you commit.

  1. Which tools are used, and at which stage of the process
  2. Whether any of the roles are located in New York City
  3. Applicant outcomes for the period, with demographics
  4. Whether the tool scores candidates or passes them
  5. Your target publication date, if you have one

What happens next

  1. You send the five items we need.
  2. We call to scope it within one business day.
  3. Nothing is charged until you approve the scope.
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Sources & standing

Where this page gets its facts

Where the claims on this page come from, and what they are worth - stated, not assumed.

What it is drawn from

  • New York City Local Law 144 of 2021
  • DCWP implementing rules
Effective
1 January 2023
Enforced from
5 July 2023

What it means

  • General information about what the law requires — not legal advice, and no professional relationship.
  • Where a scope question is genuinely arguable, our reports say so rather than pick the convenient answer.

Scope & limitation

  • Do not rest a binding decision on it; engage qualified counsel.
  • Use it as a starting point for a scoping conversation, not as your final word.

Something on this page out of date?

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