VANDAMLocal Law 144 Audit
A bias audit.The publication pack to go with it.
An independent bias audit, a public results summary and candidate-notice drafts for hiring tools covered by NYC Local Law 144. The engagement starts by establishing which tools and uses are within scope.
$8,000 annual · repeats every year
Impact ratio = a group’s selection rate
÷ the most selected group’s rate
Black or African American42.2% ÷ 51.7% = 0.82
| Group | Applicants | Moved forward | Selection rate | Impact ratio |
|---|---|---|---|---|
| Hispanic or Latino | 412 | 181 | 43.9%181 of 412 | 0.85 |
| White | 806 | 417 | 51.7%417 of 806 | 1.00 |
| Black or African American | 377 | 159 | 42.2%159 of 377 | 0.82 |
| Native Hawaiian or Other Pacific Islander | 38 | 17 | 44.7%17 of 38 | Left out of the ratios: under 2% of the data |
| Asian | 653 | 321 | 49.2%321 of 653 | 0.95 |
| American Indian or Alaska Native | 61 | 26 | 42.6%26 of 61 | 0.82 |
| Two or More Races | 220 | 96 | 43.6%96 of 220 | 0.84 |
00.801.00 |
Local Law 144 sets no pass mark and requires no particular action on the results; anti-discrimination law still applies. The dashed line at 0.80 is the four-fifths rule of thumb from federal EEOC guidelines, a common benchmark outside Local Law 144.
The audit year, date by date.
- Independent bias audit datedSelection rates and impact ratios by sex, by race and ethnicity, and by both together. The tool may be used for one year from this date.
- Summary posted on the careers pageThe audit date, the source of the data, applicant counts, rates and impact ratios for every category, the unknown-category count, and the date the tool is first used.
- Candidate notice postedOn the careers page, in the job posting, or by mail or email, at least 10 business days before use. It says how to ask for an alternative process or an accommodation.
- Tool first usedThis is the distribution date stated in the published summary.
- Next audit, plannedBooked six weeks before the year runs out, so the new summary is up in time.
- One year since the auditUse continues only with a newer audit in place. Each summary stays posted for at least six months after the tool was last used.
Few employers publish the audit, and few get checked.
- 18/391
- New York City employers studied had posted a bias audit. Thirteen posted the required notice.
Cornell and Data & Society, 2024. - 1:17
- The city reviewed 32 companies and found one issue. State auditors reviewing the same companies found at least 17.
NY State Comptroller, December 2025. - $1,500
- maximum penalty per repeat violation, and every day a tool runs out of compliance counts as a separate one.
Local Law 144.
Bring the tool, the audit and the notices together.
Hiring software can play different roles in a decision, so the first question is how your organization actually uses it. For covered automated employment decision tools, New York City has enforced Local Law 144 since July 5, 2023. The tool needs a bias audit dated within one year of its use, a published summary of the results, and a notice to candidates and employees 10 business days before use.
We assemble that work into one traceable file for your HR and legal teams. The audit ties its results to the data and method behind them. The publication pack holds the summary and notice drafts for your review, and records where and when each one has to appear.
What HR and legal work through.
One audit file per tool. It opens on the scope assessment, then the dated audit with its rates and impact ratios, then the public summary and the candidate notice drafts. Each document shows its date, its source data and who still has to review it before anything is published.
HR describes how each tool is used in plain words, and that description feeds the scope assessment. Legal reviews the summary and notices in the same file. A calendar keeps the dates that matter in view: the audit date, the posting dates, the first use and the point a year later when a newer audit has to be in place.
What every audit file holds.
Your tools and data differ. The file is built the same way each year.
Tool inventory
The tools in your hiring and promotion process, with version and use.
Scope assessment
Which uses are covered and why, written for HR and legal review.
Audit data
The records the results are calculated from, with dates, counts and the unknown category.
Rates and ratios
Selection or scoring rates and impact ratios for each required category.
Intersectional results
Sex and race or ethnicity together, as the audit requires.
Supporting calculations
Every figure traceable to the data and method behind it.
Public summary
A dated summary of the results, prepared for publication.
Notice drafts
Candidate and employee notices, with where and when each has to appear.
How the audit file is prepared.
Confirm the tool and use
We inventory the relevant tools and document their role in hiring or promotion. The scope assessment determines which uses are covered and defines the work needed for the engagement.
Tools in hiring - Resume screener · ATScovered
- Interview schedulernot covered
- Assessment test scoringcovered
- Promotion reviewnot used
Perform the independent audit
The auditor documents the data, method and required selection or scoring rates and impact ratios. The results include the applicable category and intersectional breakdowns, with the supporting calculations retained.
Impact ratios · example Prepare the publication materials
We prepare a dated public summary and the applicable candidate-notice drafts. Your team receives the results, supporting references and a record of required timing and placement for review and publication.
Publication file - Public summary, datedready for review
- Candidate notice, 10 business daysdraft
- Careers page placementagreed
- Next audit duewithin a year
Dated once.
Due again within the year.
The city requires a bias audit within one year of the tool’s use, so a covered tool that stays in use needs a newer audit every year. The engagement repeats annually, and the file, method and data requests carry over.
Yearly audit
New data, the same method, and a new dated summary and notice drafts.
Scope review
When a tool, its version or its use changes, we check whether the scope assessment still holds.
Audit calendar
The audit date, posting dates, first use and one-year mark tracked for each tool.
HR and legal check-in
A session before each audit on tool changes, data and placement.
What you
receive.
Tool inventory
The tools, their uses and the scope assessment.
Bias audit
Category and intersectional results, with the required impact ratios.
Public summary
A results summary prepared for publication.
Candidate notices
Drafts and a record of where they need to appear.
Where the audit leads.
Each next step has its own service.
DCWP’s AEDT complaint process is ineffective in ensuring that all complaints related to non-compliance with LL144 are routed to DCWP.New York State Comptroller, audit of city enforcement, December 2025
Before you ask.
Does Local Law 144 apply to our tools?
That depends on how each tool is used in hiring or promotion decisions, which is why every engagement starts with a scope assessment. We document the use and the reasoning, and your legal team makes the final call.
What data do you need from us?
Records of the tool’s use, with the outcomes and the sex and race or ethnicity categories applicants reported. Applicants with an unknown category are counted and shown separately.
What if an impact ratio is low?
Local Law 144 sets no pass mark. The audit reports the results, and what they mean for your hiring is a question for your legal team, since other anti-discrimination laws still apply.
Is this legal advice?
No. We deliver the audit, the summary and the notice drafts. Your HR and legal teams review them and decide what is published, where and when.