INTERACTIVE GUIDE

NYC LL144 Compliance Checklist

Your complete, interactive guide to achieving NYC Local Law 144 compliance. Track your progress through 6 phases over 8 weeks.

30 Action Items

8-Week Timeline

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Your Compliance Roadmap

Week 1-2: Inventory & Documentation

Identify all AI tools and gather required documentation

Create comprehensive list of all AI tools used in hiring processDocument tool names, vendors, and implementation datesCalculate annual volume of candidates affected by each toolIdentify which employment decisions each tool influencesDocument data sources and data flows for each tool

Week 3: Bias Audit Planning

Select an independent auditor and plan the audit methodology

Select an independent third-party auditor (not affiliated with the vendor)Define audit scope: which tools, time periods, and decision pointsDetermine protected categories to analyze (gender, race/ethnicity, age, etc.)Establish statistical methodology (selection rate, impact ratio, 80% rule)Set audit timeline and deliverables

Week 4-5: Data Collection & Analysis

Gather hiring data and conduct the bias analysis

Collect historical hiring data for each AI tool (minimum 6 months)Calculate selection rates by protected category for each toolApply the 4/5ths rule (80% rule) to identify adverse impactDocument any categories where adverse impact is detectedPrepare preliminary findings report

Week 6: Remediation & Documentation

Address findings and prepare required documentation

Develop remediation plan for any tools with adverse impactPrepare candidate notification language (required by LL144)Document audit methodology and findings in formal reportCreate public summary of audit resultsUpdate candidate communications with AI usage disclosures

Week 7: Internal Review & Approval

Review findings with stakeholders and get leadership sign-off

Present audit findings to HR leadership and legal teamReview remediation plan and assign ownership for each action itemObtain sign-off from legal counsel on audit reportUpdate internal policies to reflect audit findingsSchedule next annual audit date (LL144 requires annual audits)

Week 8: Publication & Compliance

Publish required disclosures and finalize compliance

Publish audit summary on company website (required by LL144)Update job postings with AI usage notificationsFile required documentation with NYC DCWPImplement ongoing monitoring process for AI toolsSet calendar reminder for next annual audit

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