NYC Local Law 144 requires a yearly independent bias audit and 10 business days' notice to candidates before you use an "automated employment decision tool" to assess them. For a startup hiring engineers, the real question is narrower: does your AI resume screener or AI interview count as one, and is the role "in the city"? A fully remote engineering job tied to a New York office counts, according to the city's own FAQ. That catches more startups than you'd think.
This is general information, not legal advice. If your process touches New York, have employment counsel read your setup.
Key Takeaways
- An AEDT is a tool using machine learning, statistics, analytics or AI that "substantially assists or replaces" discretionary hiring decisions.
- The law covers jobs located at a NYC office, including fully remote jobs whose associated location is a NYC office.
- You need a bias audit within the past year, by an independent auditor, with results published, plus notice to NYC-resident candidates 10 business days before use.
- A December 2025 State Comptroller audit called the city's enforcement "ineffective." Don't plan around weak enforcement lasting.
What NYC Local Law 144 covers
The law was passed in 2021, took effect January 1, 2023, and enforcement began July 5, 2023, according to the DCWP FAQ. DCWP is the city agency that enforces it.
A tool is an AEDT if it meets all three tests in the FAQ. It "uses machine learning, statistical modeling, data analytics, or artificial intelligence." It "helps employers and employment agencies make employment decisions." And it "substantially assists or replaces discretionary decision-making."
The third test is where most arguments happen. DCWP's rules spell it out: the tool is in scope if you rely only on its score, weight it more than any other factor, or let it overrule a human. Interviewing the tool's top ten and nobody else is relying only on its score. So is auto-rejecting everyone under a cutoff.
The law also has a scope limit people miss. It does not cover scanning a resume database, outreach, or inviting people to apply. It covers assessing people who applied for a specific position, or employees up for promotion. AI sourcing tools that find passive candidates generally sit outside it; AI screening of your applicants generally sits inside.
Does it apply to remote engineering jobs?
The FAQ says a job is "in the city" if the job location is an NYC office at least part time, or "the job is fully remote but the location associated with it is an office in NYC," or the employment agency is in NYC.
So a Brooklyn-headquartered startup hiring a remote backend engineer is covered for that role. A San Francisco startup with no New York office is generally not, even if some applicants live in Queens. Notice, though, goes to "employees and job candidates who are residents of New York City," so watch both the job and the person.
The compliance checklist
| Requirement | What it means in practice |
|---|---|
| Bias audit | An audit within the past year calculating selection or scoring rates and impact ratios by sex, race/ethnicity and intersectional categories |
| Independent auditor | Not your employee, not the vendor's, not involved in building or using the tool, no financial stake. DCWP keeps no approved list |
| Publish results | A summary of the latest audit, plus the date you started using the tool, on your careers site before use |
| Notice | To NYC-resident candidates, 10 business days before use: that an AEDT is used, the qualifications it assesses, and how to request an accommodation |
| Notice channel | In the job posting, by mail or email, or on the careers website |
Many AI hiring vendors commission a bias audit of their tool and hand it to customers. Ask for it. Check the auditor's independence and the date; an audit from 18 months ago doesn't satisfy a "within the past year" rule.
How strict is enforcement?
Penalties under the law (section 20-872) are "not more than $500 for a first violation" and violations on the same day, then "not less than $500 nor more than $1,500 for each subsequent violation." Each day of non-compliant use is a separate violation, and each missed notice is too. Small per violation, but it adds up across a hiring season.
Actual enforcement has been weak. The New York State Comptroller audited DCWP's enforcement from July 2023 to June 2025 and, in a report published December 2, 2025, called it "ineffective," per DLA Piper's summary. Test calls to 311 about AEDT problems were improperly routed 75% of the time. DCWP reviewed 32 published bias audits and found 1 issue; the Comptroller found at least 17 potential issues in the same audits. DCWP agreed to most of the recommendations.
My read: a law with a public audit saying it's under-enforced is a law about to get enforced. Also note that discrimination claims about AEDT use go to the NYC Commission on Human Rights, separately from DCWP's audit and notice rules. Low DCWP fines don't cap your exposure on discrimination.
A Concrete Version
A 40-person startup headquartered in Manhattan hires 12 engineers this year, all remote. It uses an AI tool that scores recorded technical interviews 1 to 5 and the recruiter auto-rejects anyone below 3.
That's an AEDT, the roles are "in the city," and here's the work:
1. Ask the vendor for its latest independent bias audit. If it's dated within the past year and covers this tool, publish the summary on the careers page.
2. Add a notice block to every job post: that an automated tool evaluates the recorded interview, what it assesses (problem solving, communication, system design), and an email for accommodation requests.
3. Post the notice on the careers page now. Per DCWP's FAQ, you can start using the tool 10 business days after that, for any role, regardless of when each job is posted.
4. Keep records of who was scored and when.
One afternoon of setup. The alternative, if DCWP starts counting, is up to $500 for the first violation and $500 to $1,500 for each one after, where every day of non-compliant use and every missed candidate notice counts separately.
A cheaper alternative: drop the auto-reject. If a human reviews every interview and the score is one input, you're arguing the tool doesn't "substantially assist or replace" the decision. Ask counsel how strong that argument is for your setup.
The Honest Counterpoint
For most early-stage startups, LL144 is not your biggest AI hiring risk. If you have no NYC office and hire a handful of engineers a year by hand, it probably doesn't apply at all, and spending a week on it is a poor use of a founder's time. California's FEHA rules and Illinois' notice law reach more companies; our AI hiring compliance checklist covers them together.
The other side: the "substantially assists" test is narrower on paper than in practice. If your team always follows the tool's ranking, calling it "one input" is a story a regulator may not buy. The honest fix is to make the human review real.
Where Ruzora fits: our AI-led interview and coding assessment vet engineers for our own bench before any client sees them, and the client makes the hiring decision. We're building a decision audit trail, but it isn't live yet. The same logic applies to us: if you pick who to interview purely from a scored shortlist Sol, our hiring agent, sends you, list it in your AI-tool inventory and keep a human reading every profile. Whether a vendor's pre-vetting counts as your AEDT use is a question for your lawyer, not for a blog post.
Frequently Asked Questions
What is an AEDT under NYC Local Law 144?
A computer-based tool using machine learning, statistical modeling, data analytics or AI that helps make employment decisions and substantially assists or replaces discretionary decision-making. Resume scorers and AI interview graders that drive rejections are typical examples.
Does NYC Local Law 144 apply to remote jobs?
It can. The DCWP FAQ says a fully remote job counts as "in the city" if the location associated with it is an office in NYC. Notice is owed to candidates who are NYC residents.
What are the penalties for violating Local Law 144?
Up to $500 for a first violation, then $500 to $1,500 for each subsequent one. Each day of non-compliant use and each missed notice counts as a separate violation.
The Bottom Line
NYC Local Law 144 matters if your engineering roles tie to a New York office and an AI tool drives who moves forward. Get the vendor's audit, publish it, put the notice in the job post, and keep real human review in the loop. Enforcement has been weak; the Comptroller's audit suggests that won't last.
Want engineers who already passed a structured coding assessment and AI-led interview, with your team making the final call? See how we vet.
Roberto Espinoza is CEO of Ruzora, which helps US startups hire pre-vetted senior LATAM engineers, with a vetted shortlist in 72 hours. See available engineers.
