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

AspectNYC Local Law 144EU AI Act
JurisdictionNew York CityEuropean Union (27 member states)
Effective DateJuly 5, 2023August 2024 (phased enforcement through 2027)
ScopeAutomated Employment Decision Tools (AEDTs)All AI systems used in employment — classified as high-risk
Penalties$500-$1,500 per violationUp to €35 million or 7% of global annual turnover
Audit RequirementAnnual independent bias auditConformity assessments, ongoing monitoring, and documentation
Key ProvisionFocus on disparate impact in selection ratesComprehensive 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

  1. 1If you operate in both jurisdictions, build for EU AI Act compliance first (it is more comprehensive)
  2. 2LL144 annual audits satisfy part of EU AI Act conformity requirements
  3. 3Implement continuous monitoring to meet EU AI Act ongoing obligations
  4. 4Use OnHirely multi-regulation mode to generate reports for both frameworks simultaneously

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