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US State·In Effect·Effective January 1, 2023

New York City Automated Employment Decision Tool Law

Dates and status re-checked against primary sources on October 11, 2026. How we verify

Took effect January 1, 2023, with enforcement beginning July 5, 2023. Requires employers and employment agencies in New York City to conduct independent bias audits of AI tools used in hiring decisions, publish audit results, and notify candidates that automated decision tools are being used.

What this means for your team

If you use any AI tool to screen, rank, or select job candidates for positions in New York City — including resume screening, video interview analysis, or skill assessment tools — you must commission an independent bias audit annually, publish the results, and notify applicants. Enforcement has been thin so far: a December 2025 New York State Comptroller audit (Report 2024-N-6) found DCWP has an ineffective system to address compliance, with only two AEDT complaints received from July 2023 to June 2025. DCWP reviewed 32 company websites (22 employers and 10 AEDT vendors) and found one instance of potential non-compliance; the Comptroller's review of the same companies found at least 17. Commentators read that as a sign of higher risk ahead, not lower.

Key requirements

  • Independent bias audit of AEDT before use and annually thereafter
  • Publish bias audit summary on company website
  • Notify candidates at least 10 business days before using AEDT
  • Each day an AEDT is used in violation, and each missing notice, counts as a separate violation
  • Candidate and employee notices are owed to people who reside in New York City
Penalties

Civil penalty of up to $500 for a first violation and each additional violation on the same day, and $500 to $1,500 for each subsequent violation; enforced by the NYC Department of Consumer and Worker Protection

Enforcement examples

Rite AidFTC · 2023

From 2012 to 2020, Rite Aid used AI facial recognition in hundreds of stores to flag suspected shoplifters. The FTC said the system produced false matches that led staff to accuse customers of wrongdoing, that its actions disproportionately affected people of color, and that Rite Aid did not test or document the system's accuracy.

Outcome: Rite Aid is prohibited from using facial recognition for surveillance for five years. It must delete, and direct third parties to delete, images collected by the system and any algorithms built from them, and implement an information security program overseen by top executives.

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