NYC Local Law 144 — AEDT bias audit requirements take effect with July 2026 enforcement update

What the law is now

NYC Local Law 144 requires employers and employment agencies that use automated employment decision tools — software that substantially assists or replaces discretionary employment decisions — to conduct and publish independent bias audits of those tools before use and annually thereafter. Employers must also notify candidates that an AEDT is being used and provide an alternative assessment process on request.

What just shifted

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What this adds: DCWP's June 2026 amendment clarifies that AI-powered resume screening, scoring, and ranking tools qualify as AEDTs even when a human reviewer makes the final selection, resolving prior ambiguity about tools that produce ranked candidate lists rather than yes/no outputs. The amendment also specifies that the bias audit must now include intersectional analysis across race-sex combinations, not just the single-axis categories in the original rule.

What this puts in question: Whether generative AI tools used to draft or evaluate interview questions, score interview recordings, or assess cover letters qualify as AEDTs — DCWP indicated guidance on this category is forthcoming.

What clients should weigh

·Do you use any tool that ranks, scores, or filters job applicants for NYC-based roles — including ATS features, LinkedIn Recruiter, HireVue, or other AI-assisted screening — and does it qualify as an AEDT under the amended definition?

·Is your most recent bias audit current (within 12 months) and does it include the intersectional race-sex analysis now required under the June 2026 amendment?

·Is your candidate disclosure in place — the notice telling NYC applicants that an AEDT is used, before the tool evaluates them — and is your alternative assessment process documented and actually available?

·The amendment resolves the ranked-list ambiguity in DCWP's favor. If you previously concluded that a ranking tool was not an AEDT, that analysis may no longer hold, and the audit and notice obligations are triggered.

NYC Admin. Code § 20-871; DCWP Rules, 55 RCNY ch. 7 (2023), amended June 2026 ›

Watch for

· EEOC AI and employment discrimination guidance, Q3 2026 expected

· Colorado SB 24-205 AEDT provisions, effective January 2027

· Illinois AIVA enforcement referrals, 2026 enforcement cycle

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