AEDT Audits
Independent · Flat Fee
Effective 2026 · Remote U.S. Engagements
§ Memo
To: U.S. Employers Using AI-Assisted Hiring / Re: Exposure Under NYC Local Law 144

Every year, an independent bias audit of your AEDTs. Delivered in seven business days.

Since July 2023, any employer evaluating a candidate who resides in New York City using an automated employment decision tool has been subject to NYC Local Law 144.1 The statute requires an annual independent bias audit, public disclosure of its results, and ten business days' notice to affected candidates.

In December 2025, the New York State Comptroller concluded that enforcement of the law by the Department of Consumer and Worker Protection had been ineffective.2 DCWP has since committed to a stricter enforcement posture, including proactive investigation of non-compliant employers.3

This engagement produces the documentation required to satisfy the audit, publication, and notice obligations under the statute — at a flat fee, and within one business week.

Request a scoping consultation → Review applicability criteria
§ 01.
Context

A statute that reaches most remote U.S. employers — not only those headquartered in New York.

Local Law 144 applies whenever an AEDT is used to evaluate a candidate who resides in NYC, regardless of where the employer is based. A California company hiring a remote worker in Brooklyn is as squarely within scope as a Midtown Manhattan firm.

The category of covered tools is broader than most employers assume. It includes applicant tracking systems with AI-assisted ranking, video interview platforms that produce fit scores, assessment vendors generating classifications, and recruiting chatbots that recommend candidates. The compliance obligation rests with the employer — not the vendor.

"Seventy-five percent of test calls to the NYC 311 hotline regarding AEDT issues were improperly routed. DCWP reviewed the websites and bias audits of 32 companies and identified one issue of non-compliance. Our auditors reviewed the same companies and identified at least 17 instances of potential non-compliance." — Office of the New York State Comptroller, December 20252

Many employers have understandably treated the first two years of the law as a grace period. That posture is no longer tenable. The stated enforcement priority for 2026 is to close the gap between non-compliance and consequence.

§ 02.
Exposure

The statute authorizes daily, per-violation penalties.

Under Local Law 144, a first violation carries a civil penalty of $500. Subsequent violations, including each day an AEDT is used without a valid audit, may be assessed at $500 to $1,500 per day.4 Each failure to provide the required candidate notice can also constitute a separate violation.

Illustrative exposure, conservative
A mid-market employer operating an AEDT without a valid audit for thirty days.
Low estimate
$15,000
30 days × $500
High estimate
$45,000
30 days × $1,500
Audit fee
$1,500
Annual, flat

The figures above address audit-violation penalties only. They do not include separate per-candidate notice violations, potential disparate impact claims under Title VII or state equivalents, or reputational exposure from publicly disclosed non-compliance.

§ 03.
Applicability

Determination: an employer is likely within scope if two or more of the following are true.

  1. The employer uses an applicant tracking system with AI-assisted candidate ranking, matching, or screening — including Workday, Greenhouse, iCIMS, Ashby, Lever, or comparable platforms with such features enabled.
  2. The employer uses a video interview, pre-hire assessment, or chatbot platform that produces a score, classification, or recommendation regarding candidates — including HireVue, Paradox, Pymetrics, Harver, or comparable vendors.
  3. The employer posts remote or hybrid roles that are open to candidates anywhere in the United States.
  4. The employer has not completed a bias audit of its covered tools, by an independent third party, within the preceding twelve months.

Conditions (a) or (b) combined with (c) or (d) are generally sufficient to establish coverage. Edge cases — tools used only for resume parsing, tools not producing a simplified output, or human-reviewed final decisions — are addressed during scoping.

§ 04.
Engagement

A single engagement satisfies the statute for twelve months.

Fee
$1,500 flat
One AEDT per audit. Multi-tool engagements quoted separately.
Turnaround
Seven business days
From receipt of candidate data export.
Validity
Twelve months
From the date the signed report is issued.
Scope
Statutory requirements
Selection & scoring rates, impact ratios, intersectional analysis, four-fifths rule.

Deliverables

/ 01
Signed bias audit report
A PDF report computing selection rates, scoring rates, and impact ratios across race, sex, and intersectional categories, with four-fifths rule analysis, small-group exclusions documented, and a statement of auditor independence.
/ 02
Public summary page
A ready-to-host HTML summary containing the audit date, data source, candidate counts by category, selection and scoring rates, and impact ratios — formatted to the publication requirements under DCWP rules.
/ 03
Candidate notice template
A compliant ten-business-day candidate notice, covering tool usage, assessed qualifications, data sources, and alternative-selection-process request language, suitable for use in an ATS or careers page.
§ 05.
Methodology

An audit is only as sound as the hands that conduct it.

The term "independent auditor" is defined narrowly under DCWP's final rule: a person or organization with no employment relationship with the employer, no role in developing or using the AEDT, and no financial interest in either.5 This engagement satisfies all three conditions.

Framework
DCWP Final Rule (6 RCNY Ch. 5, Subch. T), incorporating the EEOC four-fifths rule and federal disparate impact doctrine.
Statistics
Selection rate, scoring rate, and impact ratio computations performed using open-source, peer-reviewed fairness libraries (fairlearn, aif360), with results independently verifiable.
Categories
All race and ethnicity categories and sex categories specified in the EEO-1 Component 1 reporting framework, plus all intersectional combinations required by DCWP guidance.
Small groups
Groups representing less than 2% of the evaluated candidate pool are excluded from the impact ratio analysis, with exclusion counts reported per statute.
Independence
No financial interest in any AEDT vendor or covered employer. No compensation structure contingent on audit outcome. Documented in every issued report.
§ 06.
Next step

A fifteen-minute call to determine applicability and scope.

The consultation confirms which tools fall within Local Law 144, identifies the records required for the audit, and establishes an engagement timeline. It carries no obligation and no fee.

Schedule the consultation →
Vedvyas Mahato
Principal & Independent Auditor
AEDT Audits
§
Notes
Footnotes & authorities
  1. N.Y.C. Local Law No. 144 of 2021 (in effect July 5, 2023); 6 RCNY Ch. 5, Subch. T (DCWP Final Rule adopted April 6, 2023).
  2. Office of the New York State Comptroller, Enforcement of Local Law 144 — Automated Employment Decision Tools (Dec. 2, 2025).
  3. DLA Piper, Employment Alert, "New York: Critical audit of NYC's AI hiring law signals increased risk for employers" (Feb. 2026).
  4. N.Y.C. Local Law 144 § 20-871; civil penalties of $500 for a first violation, $500–$1,500 per subsequent or continuing violation; each day of continued use without a valid audit constitutes a separate violation.
  5. 6 RCNY § 5-300 (definition of "independent auditor").