Why LL144 Compliance Matters More Than Ever in 2025
Two years after NYC Local Law 144 took effect, enforcement has matured significantly. The NYC Department of Consumer and Worker Protection (DCWP) has moved from educational outreach to active enforcement, issuing fines and conducting investigations. Employers who delayed compliance are now facing real consequences.
This guide provides an updated, comprehensive walkthrough of everything you need to know about LL144 compliance in 2025, including recent enforcement trends, updated audit best practices, and the most common mistakes employers are still making.
What LL144 Requires: A Quick Refresher
Local Law 144 mandates that any employer or employment agency using an automated employment decision tool (AEDT) in New York City must:
- Conduct an independent bias audit within one year of using the AEDT
- Publish a summary of audit results on their website
- Notify candidates at least 10 business days before the AEDT is used
- Provide an alternative process upon candidate request
An AEDT is defined as any computational process derived from machine learning, statistical modeling, data analytics, or AI that issues a simplified output used to substantially assist or replace discretionary decision-making for employment decisions.
2025 Enforcement Trends
Several important enforcement patterns have emerged:
- Proactive investigations: DCWP is not waiting for complaints. They are actively reviewing company career pages and job postings for AEDT use
- Third-party vendor audits: Regulators are examining whether vendors themselves have been audited, not just the employers deploying the tools
- Candidate notice scrutiny: Several fines have been issued specifically for inadequate candidate notification, even when the bias audit itself was compliant
- Stacking violations: DCWP is interpreting each day of non-compliant use as a separate violation, leading to substantial cumulative fines
Step-by-Step Compliance Checklist for 2025
Step 1: Inventory Your AEDTs
Catalog every tool in your hiring pipeline that uses AI, ML, or statistical modeling. Include:
- Resume screening and parsing tools
- AI-powered assessments and skills tests
- Video interview analysis platforms
- Chatbot-based screening tools
- Candidate ranking and matching algorithms
Many employers miss tools embedded in their ATS or HRIS platforms. If the vendor uses AI to score, rank, or filter candidates, it is likely an AEDT.
Step 2: Engage an Independent Auditor
The auditor must be independent — meaning no financial interest in the AEDT's development or deployment beyond the audit itself. The audit must be conducted using either historical deployment data or test data.
Key requirements for the audit:
- Calculate impact ratios for sex/gender categories
- Calculate impact ratios for race/ethnicity categories (using EEOC categories)
- Cover a minimum of one year of deployment data when available
- Be completed within one year before the AEDT is used
Step 3: Review and Remediate
If impact ratios fall below the 0.80 threshold for any group, work with your vendor to understand the root cause. Common remediation approaches include:
- Retraining the model on more balanced data
- Removing or adjusting features that serve as proxy variables
- Implementing post-processing fairness constraints
- Switching to a less biased alternative tool
Step 4: Publish Your Audit Summary
The published summary must include:
- The date of the most recent audit
- The distribution date of the AEDT
- Impact ratios for all required categories
Best practice is to host this on a dedicated compliance page accessible from your careers site.
Step 5: Update Candidate Notices
Notices must be provided at least 10 business days before AEDT use and must include:
- That an AEDT will be used in the assessment
- What job qualifications or characteristics the AEDT evaluates
- Data source and retention information
- Instructions for requesting an alternative process or accommodation
Step 6: Establish Ongoing Compliance
- Schedule annual re-audits before the prior audit expires
- Monitor for changes in your AEDT that might require interim audits
- Keep records of all compliance activities for at least three years
- Train hiring managers on AEDT use policies and candidate notice requirements
Common Compliance Pitfalls
- Assuming your ATS vendor handles compliance for you — the employer remains legally responsible regardless of vendor claims
- Using test data instead of real deployment data — while permitted, regulators prefer audits based on actual historical data
- Publishing audit results in an inaccessible location — the summary must be easy to find, not buried in a terms-of-service page
- Failing to update the audit after model changes — significant changes to an AEDT may require a new audit before the annual cycle
- Incomplete candidate notices — omitting any required element can result in a separate violation
How OnHirely Streamlines LL144 Compliance
OnHirely automates the most time-consuming parts of LL144 compliance. Upload your hiring data, and the platform calculates impact ratios, runs statistical significance tests, generates a publication-ready audit summary, and provides remediation guidance — all within minutes. Annual re-audits become a routine process rather than a multi-month project.