Local Law 144 checklist for startups (NYC AEDT compliance)
For startups with NYC candidates or NYC roles. Twelve-minute read. Not legal advice — consult counsel for guidance on your specific deployment.
12-minute read · Last updated 2026-05-28
TL;DR
If your startup uses any tool that produces a score, ranking, or classification of NYC candidates and that output substantially assists a hiring decision, you have three concrete obligations: (1) commission an independent bias audit within the previous year, (2) publish the audit summary on the role page, and (3) give candidates at least 10 business days' notice plus a documented alternative selection process. Annual re-audit. Penalties are per-violation per-candidate. This is operational compliance, not a one-time form — but the surface a competent vendor provides covers most of the work. Not legal advice; talk to counsel.
1. Who Local Law 144 actually applies to
LL144 binds the employer (and any employment agency acting on the employer's behalf), not the vendor. It applies whenever an employer uses an Automated Employment Decision Tool to substantially assist or replace a discretionary decision to hire or promote a candidate based in NYC, or for a role based in NYC. There is no employee-count threshold and no carve-out for startups. A two-person company hiring a remote-eligible role open to NYC is in scope.
The bright line is the candidate's location and the role's location. If neither touches NYC, LL144 does not apply (other jurisdictions might — Illinois's AIVIA, the EU AI Act, California's AB-331, etc.). If either touches NYC, you are inside.
For the official definitions, see the NYC DCWP AEDT page. For the term itself, see the glossary entry on AEDT.
2. What counts as an AEDT
DCWP's implementing rules define an AEDT as a computational process (machine learning, statistical modelling, or other AI) that issues a simplified output — a score, classification, or ranking — used to substantially assist or replace a discretionary employment decision. "Substantially assists" means one of three things: (1) the output is the sole or main criterion, (2) it is weighted more than any other criterion, or (3) it is used to overrule a conclusion from a human.
What is in: résumé filters that drop applicants below a threshold, AI interview agents that score candidates against a rubric (when that score weighs heavily), assessment platforms that produce a pass/fail. What is probably out: a tool that surfaces résumés for a human to read without producing a score, a calendar scheduler, a CRM. The boundary is "does the tool produce a number a recruiter substantially weighs."
The underlying scoring method matters for the audit — see rubric scoring for how per-criterion scoring is easier to audit than composite-only.
3. The bias audit summary requirement
LL144 requires an independent bias audit within the previous year, plus a public summary of that audit. The auditor must be independent of both the employer and the AEDT vendor. The audit reports selection rates and adverse impact ratios across the EEO-1 sex categories, race/ethnicity categories, and the intersection of the two.
The summary has to be posted publicly. The standard pattern is a single page on the careers site (or linked from each role posting) with the date of the audit, the auditor, the categories audited, the selection rates, and the calculated adverse impact ratios. The four-fifths threshold (AIR < 0.80) is the headline check.
4. The candidate notice rule (10 business days)
At least 10 business days before the AEDT is used on a candidate, the employer must notify them of: (a) that an AEDT will be used, (b) the job qualifications and characteristics the AEDT assesses, and (c) the candidate's right to request an alternative selection process or a reasonable accommodation.
The notice can be posted on the role page, on the careers page, or sent directly. The 10-business-day clock starts from the notice — not from the application date. The alternative selection process for candidates who decline is non-optional and cannot disadvantage the candidate. Practically, that usually means a human recruiter conducts the screen using the same questions and rubric. Document the alternative in advance.
How Vettika helps
Vettika produces the per-session audit log and the LL144-shaped summary export an independent auditor needs to produce the bias audit, plus a candidate-notice template you can post with the 10-business-day clock built in. The recruiter is always the final decision-maker — we never auto-reject. We are not the auditor — that has to be a third party by law. Full posture on /product/compliance and pricing for what is included at each tier.
5. What the audit report must contain
The audit summary made public should include: the date of the audit, the auditor's name and independence statement, a description of the AEDT and what it assesses, the selection rates per demographic category, the adverse impact ratios computed against the most-favored group, and the data sample used for the audit (number of candidates per category, time window).
What the auditor needs from your vendor: a per-session audit log capturing the criteria used, the per-criterion scores, the justification text, the pinned model and prompt versions, the consent records, and the candidate's self-identified demographic categories. A vendor that hands you only a final pass/fail without the underlying record is not LL144-shaped — auditors cannot work from that.
6. Vendor questions to ask before signing
A vendor that claims to be "LL144-ready" should be able to answer all of these without going to legal. Save this list as your AEDT vendor RFP.
Do you provide a per-session audit log capturing criteria, scores, justifications, model versions, and consent records?
Is your audit log exportable in a format an independent bias auditor can use directly?
Do you provide a candidate-notice template I can post on the role page with the 10-business-day clock?
Is your scoring per-criterion, or do you produce a single composite score? (Composite-only scores are harder to audit.)
Do you ever auto-reject candidates, or is the recruiter always the final decision-maker?
How are model versions pinned per session for replay?
Who has used your platform to satisfy LL144 before, and which independent auditors did they use?
How is candidate audio handled — kept or destroyed on hangup?
What is your posture on EU AI Act and on Nigerian NDPR if you also operate there?
7. The startup checklist
Ten items. Work through them in order. If you cannot answer one, that is the place to spend the next hour.
LL144 startup checklist
This checklist is informational and is not legal advice. Confirm with counsel before relying on it for any specific deployment, audit, or candidate notice.
FAQ
My startup is not in NYC. Does LL144 apply to me?+
It can. LL144 binds the employer using the AEDT, and it applies when the candidate is in NYC or the role is based in NYC. A San Francisco startup posting a remote role open to NYC candidates is in scope. A startup that has never hired anyone in NYC is not — yet. The cheap move is to run AEDT-compliant from day one so a future NYC hire doesn't reset your compliance.
Is one bias audit enough forever?+
No. The audit must be from the prior year — i.e. within the last 12 months. If the AEDT changes (new model version, new scoring weights, new training data), most counsel will recommend re-auditing earlier. Annual re-audit is the safe default.
What happens if a candidate declines the AEDT?+
You must offer an alternative selection process. The alternative cannot disadvantage the candidate. Practically: a human recruiter conducts the screen using the same questions and rubric. Document the alternative in advance so you do not have to invent it on the spot.
Do small startups actually get fined for LL144 non-compliance?+
DCWP has issued violations and fines since enforcement began in 2023. Small businesses have been included. Penalties are per-violation per-candidate, which scales fast on a single hiring cycle. Beyond fines, a public DCWP enforcement action is a recruiting and PR problem most startups do not want.
Does LL144 require me to use a specific bias auditor?+
No specific auditor is required, but the auditor must be independent of the employer and of the AEDT vendor. They cannot have a financial interest in the result. Ask any vendor who claims LL144-readiness for a list of auditors their other customers have used; the major ones publish their methodology.
The audit log ships with the product. Not a six-figure add-on.
Per-session audit records, exportable summary, candidate-notice template. From interview one.