Does NYC Local Law 144 apply to a staffing agency's screening tools?
Yes. The law covers employment agencies by name, not only the employers they place for. If your desk uses an AI or algorithmic tool to screen candidates for New York City roles, the bias-audit and notice duties are yours.
Answered in short
5 things that decide this
- 01NYC Local Law 144 applies to employment agencies as well as employers. A staffing agency that uses an automated employment decision tool (AEDT) to screen candidates for New York City jobs carries its own compliance duties.
- 02The law took effect on 1 January 2023, and the Department of Consumer and Worker Protection (DCWP) has enforced it since 5 July 2023.
- 03Using an AEDT requires an independent bias audit from the past year, a public summary of the results, and notice to candidates at least 10 business days before the tool is used on them.
- 04Civil penalties run up to 500 dollars for a first violation and 500 to 1,500 dollars for each one after, under the DCWP's penalty schedule. Each day of use counts on its own.
- 05A vendor's compliance claim does not discharge the duty. The obligation sits with the employer or agency using the tool, so your agency needs its own audit trail.
The law names employment agencies directly
Local Law 144 regulates automated employment decision tools used to screen candidates for employment, or employees for promotion, in New York City. Its text applies to employers and employment agencies, so a staffing firm is in scope in its own right. Where your client sits doesn't settle the question. What settles it is whether a tool substantially assists or replaces a screening decision for a New York City role.
The law defines an AEDT as a computational process built on machine learning, statistical modeling, data analytics or AI. It has to issue a simplified output: a score, a class or a recommendation. A parser that only lifts fields out of a resume isn't screening anyone. A tool that ranks candidates, or knocks them out on a score, is.
Your office address matters less than your placements. If you screen candidates for New York City roles, plan for the law even when the desk sits in New Jersey or Florida.
What an agency owes before the tool runs
Three duties come with an AEDT. An independent bias audit within the last 12 months, testing selection rates by sex and by race or ethnicity. A public summary of that audit on your website. And notice to candidates at least 10 business days before the tool is used on them, naming the qualifications and characteristics it assesses.
Vendors can commission the audit, and many do. Responsibility stays with the agency using the tool. So keep your own record: which tools score or rank candidates, which audit covers each one, and which notices went out for which roles.
Enforcement looked weak in 2025. Don't price that in.
A New York State Comptroller audit published in December 2025 found DCWP's enforcement of Local Law 144 badly broken. Auditors identified 17 potential violations the department's own review had missed, and 75 percent of 311 complaint calls about the law were misrouted. Weak enforcement so far is not a safe harbor. The audit itself is the pressure that changes it, and law firms were flagging increased employer risk within weeks of its release.
A compliance trail that satisfies an examiner is a build problem, and it's one we work on. Hashlogics built Shift Link, an AI workforce compliance platform, for a UK recruitment firm supplying temporary staff to healthcare and logistics. It cut manual compliance verification by 70 percent, by running the checks before dispatch instead of after. A Local Law 144 trail wants the same shape: you create the record when the tool runs, and never rebuild it when someone asks.
- Tool inventoryWhich systems score or rank candidates.
- Bias auditIndependent, within 12 months.
- Summary publishedOn the agency's public site.
- Candidate notice10 business days ahead.
- Run loggedTool, role, date, notice sent.
Local Law 144 sets the duties. The log proves you met them.
Related questions
01Is my vendor's bias audit enough?+
It can satisfy the audit requirement, but the legal duty stays with the agency using the tool. You still have to confirm the audit is independent and less than a year old, publish the summary, and send your own candidate notices. Keep copies of all of it. A vendor's marketing page is not a compliance record.
02Does the law apply if my agency has no NYC office?+
The trigger is the role and the candidate, not your address. An agency screening candidates for New York City jobs should treat itself as covered wherever the desk sits, and have counsel map its specific placements.
03What happens if we ignore it?+
Civil penalties reach 500 dollars for a first violation and 500 to 1,500 dollars for each later one, under the DCWP's schedule. Each day of use counts on its own. Missing notices and missing audits count as separate violations, so the total grows fast on a high-volume desk.
Related
- What is an automated employment decision tool (AEDT)? →The three-part definition the whole law hangs on.
- Is AI resume screening safe to use? →Bias and accuracy, the question behind the legal one.
- Software for staffing agencies →Our staffing hub: what agencies actually build.
- Shift Link: AI workforce compliance platform →Compliance checks that run before dispatch, not after.
