NYC Local Law 144: The AI Hiring Law Nobody's Enforcing (Yet)
Local Law 144 has required bias audits for AI hiring tools since July 2023. Zero enforcement in three years. Why private litigation, not DCWP, is the real threat.
How many enforcement actions has NYC brought under its AI hiring law since July 2023? Zero. A Comptroller audit confirmed DCWP didn't investigate a single complaint in the first 18 months. Three years of a law on the books and the agency responsible for enforcing it has done absolutely nothing. My read on why: DCWP doesn't have the technical staff to evaluate AI systems. They regulate home improvement contractors and tax preparers. Auditing machine learning models for demographic bias isn't something they know how to do. They're waiting for someone else to go first. That someone will be a plaintiffs' lawyer. Employment litigation firms are writing about LL144 constantly. Not for fun. They're building cases and waiting for the right defendant. What the Law Actually Requires Applies to employers and employment agencies in NYC using an "automated employment decision tool" (AEDT) for hiring or promotion. The tool has to "substantially assist or replace discretionary decision making." Keyword filter screening for "Python experience"? Probably not an AEDT. AI model scoring and ranking candidates based on resumes, video interviews, assessment data? Absolutely is. Three requirements.