NYC Local Law 144 vs. EU AI Act
Compare the US's most active local AI hiring law with the EU's comprehensive AI regulation framework.
Side-by-Side Comparison
| Aspect | NYC Local Law 144 | EU AI Act |
|---|---|---|
| Jurisdiction | New York City | European Union (27 member states) |
| Effective Date | July 5, 2023 | August 2024 (phased enforcement through 2027) |
| Scope | Automated Employment Decision Tools (AEDTs) | All AI systems used in employment — classified as high-risk |
| Penalties | $500-$1,500 per violation | Up to €35 million or 7% of global annual turnover |
| Audit Requirement | Annual independent bias audit | Conformity assessments, ongoing monitoring, and documentation |
| Key Provision | Focus on disparate impact in selection rates | Comprehensive technical documentation, human oversight, and transparency requirements |
Key Differences
- Scale of penalties: EU AI Act fines dwarf LL144 penalties (€35M vs $1,500)
- Scope: EU AI Act covers all employment AI; LL144 limited to AEDTs
- Requirements: EU AI Act demands ongoing monitoring; LL144 requires annual audit
- Documentation: EU AI Act requires extensive technical documentation; LL144 requires audit report publication
- Enforcement: LL144 enforced by NYC DCWP; EU AI Act by national authorities across 27 countries
Compliance Strategy
- 1If you operate in both jurisdictions, build for EU AI Act compliance first (it is more comprehensive)
- 2LL144 annual audits satisfy part of EU AI Act conformity requirements
- 3Implement continuous monitoring to meet EU AI Act ongoing obligations
- 4Use OnHirely multi-regulation mode to generate reports for both frameworks simultaneously
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Read moreComply With Multiple Regulations at Once
OnHirely supports multi-regulation analysis. Run a single audit and get compliance reports for NYC LL144, EU AI Act, and more.
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