The ten-business-day notice
What DCWP says about timing, and why the interval is the requirement rather than a detail of it.
New York City
NYC Local Law 144
Local Law 144 is the oldest AI hiring law in the country, and the one people most often get wrong. It is a New York City ordinance, not a New York State one. It has applied since July 5, 2023, it wants the candidate told ten business days before an automated tool is used, and it names employment agencies alongside employers.
What DCWP says the law requires
Taken from the Department of Consumer and Worker Protection's own AEDT page rather than from a summary of it.
New York City: jurisdiction and source status
- Jurisdiction
- New York City only — a municipal ordinance, not New York State law
- Law
- Local Law 144 of 2021, on automated employment decision tools (AEDT)
- Agency
- NYC Department of Consumer and Worker Protection (DCWP)
- Enforcement began
- July 5, 2023
- Core duties
- DCWP states that Local Law 144 prohibits employers and employment agencies from using an AEDT unless the tool has been subject to a bias audit within one year of its use, information about that audit is publicly available, and certain notices have been provided to employees or job candidates.
- Notice timing
- DCWP revised its roundtable materials in June 2023 to clarify that the notice must be provided 10 business days prior to use of an AEDT.
- Complaints
- Filed with DCWP; a complainant selects “Employment Agency” or “Other” as the business type, and no account is required.
- Last reviewed
- August 26, 2026
The bias audit and the notice are two different jobs
Local Law 144 gets called "the bias audit law" and "the notice law". It is both, and in most organizations the two halves sit with different people.
| The bias audit | The candidate notice | |
|---|---|---|
| What it requires | The tool must have been subject to a bias audit within one year of its use, and information about the audit must be publicly available | Certain notices must be provided to employees or job candidates, 10 business days prior to use of the AEDT |
| Who it turns on | The tool, and whoever selected it | The workflow, and whoever runs it |
| Where it usually sits | Legal, procurement, or the tool vendor | Recruiting operations |
| Does Notice Tracking help? | No. It does not perform, commission, store or publish a bias audit | Yes — approved template versions, sends, delivery events and exports |
Your bias audit stays with your auditor. Notice Tracking handles the other half: the candidate notice, the date it went out, and the record that shows it.
The ten business days are the hard part
Ten business days is more than two calendar weeks once a holiday lands in it, and all of it has to elapse before the tool is used. In a high-volume pipeline that is a scheduling problem: the notice has to go out at a point where nobody yet knows whether the candidate will matter.
That is why the timing gets missed. Nothing visibly breaks on the day. It surfaces later, when someone asks for the date the notice went out and the answer falls inside the same ten days the tool ran. How the ten-business-day notice works.
Go deeper on New York
New York State vs New York City
Does New York State have an AI hiring law? Most people guess wrong.
NYC and California together
Two live regimes with different triggers, different timing and different records.
What this means for a staffing agency
DCWP's description of the law names employment agencies alongside employers, which puts agencies squarely in scope rather than adjacent to it. The complaint route confirms it: when someone files with DCWP, one of the business types they select is "Employment Agency".
Operationally that means an agency needs to be able to show, for a named candidate, that a notice went out and when — measured in business days against the date the tool ran. That is a record created at send time. It cannot be assembled afterwards from a policy document and a recollection.
Which records to capture at send time, once volume rules out reconstructing them, is covered in candidate-level notice records for high-volume pipelines.
Common questions
Does New York City's AI hiring law apply to the whole of New York State?
No. Local Law 144 is a New York City ordinance enforced by the NYC Department of Consumer and Worker Protection. It applies to covered positions in New York City, not to New York State generally.
How much notice does Local Law 144 require?
DCWP revised its materials in June 2023 to clarify that the notice must be provided 10 business days prior to use of an automated employment decision tool.
Does Local Law 144 apply to staffing and employment agencies?
DCWP's own description of the law names employers and employment agencies together. Whether it reaches a particular placement is a legal question for your counsel.
Is a bias audit part of the requirement?
Yes. DCWP states the tool must have been subject to a bias audit within one year of its use and that information about the audit must be publicly available. That half stays with your auditor. Notice Tracking handles the notice half.
Does Notice Tracking perform the bias audit?
No. A bias audit is carried out by an independent auditor. Notice Tracking handles the candidate notice: it holds your approved template versions, sends them, records delivery and failure events as the provider reports them, and produces the export.
Ten business days is only provable if the date was recorded.
Notice Tracking preserves the approved template version, the send timestamp and the provider-returned delivery event against the candidate, so the interval can be shown rather than asserted.
This page is general information about published government requirements, last reviewed August 26, 2026. Requirements change; confirm the current text with the agency and your own counsel before relying on it.