AEDT Annual Bias Audit Expiry and Renewal

Pull the folder. Now prove today's date, not last spring's

Pull the folder of last year's AEDT audit paperwork and try to answer one question fast: which of your active automated employment decision tools has a currently valid bias audit right now — not last spring, not "sometime this year," but today. If you can't answer in under thirty seconds, you don't have a compliance program, you have an archive.

Local Law 144 doesn't hand a bias audit a fixed shelf life stamped on a calendar page. It recognizes an audit as current for roughly a year from the audit it covers — until it doesn't. And that same audit can lapse early, with no warning bell, if you change the underlying model, swap vendors, or roll the tool out to a new use case NYC-based candidates will encounter mid-cycle. Meanwhile, teams that treat last year's audit-summary PDF as permanent proof of "coverage" are exactly the pattern regulators have started flagging as thin, backward-looking documentation rather than a live compliance state.

By the end of this piece, you'll be able to build a forward-looking AEDT annual bias audit expiry and renewal cycle that tells you your real audit-currency status on any day of the year — not just the day you happen to go digging for it.

The 12-month clock behind AEDT annual bias audit expiry and renewal

Local Law 144 covers any automated employment decision tool (AEDT) — defined broadly as a computational process built on machine learning, statistical modeling, data analytics, or AI that produces a simplified output (a score, classification, or recommendation) used to substantially assist or replace discretionary hiring or promotion decisions (Perkins Coie, 2023). The law took effect January 1, 2023, with enforcement beginning July 5, 2023, after a short delay from an originally announced April date (Epstein Becker Green / Workforce Bulletin, 2023).

Three obligations sit underneath every covered AEDT: an annual independent bias audit; a public summary of the most recent audit results posted on the employer's website, alongside the AEDT's distribution date; and candidate or employee notice at least 10 business days before the tool is used, with an accessible alternative-process or accommodation route (Crowell & Moring LLP, 2023; Epstein Becker Green, 2023).

"Annual" is the operative word, and it's where most AEDT annual bias audit expiry and renewal problems start. The audit isn't a one-time certificate — it's a rolling obligation tied to the tool as actively deployed. Once roughly twelve months pass from the audit a current public summary reflects, that summary is no longer doing its job, whether or not anyone at your company has noticed.

What starts the clock — and what can reset it early

The simplest version of the clock: it starts on the date of your most recent completed independent bias audit and runs about a year. Mark that date, add twelve months, and you have a renewal deadline for that specific tool.

The complication is that the clock doesn't run in isolation from what you're actually doing with the tool. If a vendor pushes a materially different scoring model, you change vendors outright, or you extend the AEDT into a new decision point — say, moving a resume-screening tool from initial applicant sorting into promotion decisions — the audit you're relying on may no longer describe the tool you're using. LL144 doesn't spell out a precise, mechanical test for exactly what change forces an early re-audit; that's a judgment call worth confirming with DCWP or outside counsel before you treat a vendor's routine model update as automatically triggering a new audit cycle. What's not a judgment call: an audit summary describing a tool you've since materially changed isn't standing in for the tool you're now running.

This is the piece that turns a single expiry date into a genuine AEDT annual bias audit expiry and renewal cycle rather than a once-a-year fire drill: every vendor change notice, every new use case, every internal AEDT rollout needs to pass through the same question — does this reset or shorten the clock on an existing audit?

Reading your own audit-currency status without guessing

The only reliable way to answer "is this tool's audit current?" on demand is a register, not a memory. At minimum, track per tool: the tool name and vendor, the date of the most recent independent audit, the calculated expiry date, whether the public summary and distribution date are posted and current, and whether the 10-business-day candidate notice language matches what's actually deployed.

That register is the backbone behind resources like how often a bias audit is actually required in NYC and the mechanics of renewal reminders for the annual bias audit — both worth reading alongside this one if you're building the cycle from scratch.

An always-on reminder system that watches these dates and pings you automatically isn't something we sell today — that kind of continuously monitoring engine is part of what we're building toward, and if that's the kind of tooling you're waiting on, join the waitlist to hear when it ships. Right now, the register itself — kept current by whoever owns AEDT compliance — is the mechanism. It doesn't run itself, and that's the honest starting point.

What happens when the audit lapses

The statutory exposure is real and specific: civil penalties run up to $500 for a first violation (and each additional violation on the same day), $500 to $1,500 for each subsequent violation, and penalties accrue per violation, per day (Office of the NY State Comptroller, 2025). A lapsed audit that keeps a tool running past its renewal window compounds daily.

The gap between "we have an audit on file" and "our audit is currently valid" is exactly where regulators have started looking hardest.

The state's own audit function has said enforcement in practice has been inconsistent. A December 2025 Comptroller review covering July 2023 through June 2025 characterized DCWP enforcement as ineffective (DLA Piper, 2026; Office of the NY State Comptroller, 2025). Across a sample of 32 companies, DCWP's own review found minimal noncompliance — far fewer violations than the 17 the Comptroller's auditors found reviewing the same companies (Office of the NY State Comptroller, 2025). A separate academic "Null Compliance" study of 391 employers found only 18 had posted audit reports and only 13 had posted transparency notices at all (ACM FAccT, Wright & Muenster et al., 2024). Related research has also raised concerns that published LL144 audits themselves can under-report disparities where demographic data is missing or aggregation is opaque (ACM FAccT, "Auditing the Audits," 2025).

None of that is a reason to relax — it's the opposite. If regulatory follow-through has been inconsistent so far, the operational discipline of running your own renewal cycle is doing work that enforcement currently isn't doing for you. For a fuller picture of what a missed deadline actually exposes you to, see what happens if you miss the bias audit deadline.

One framing note, stated plainly: everything above describes an operations problem, not a legal opinion. Nothing here is legal advice, and none of it substitutes for confirming your specific obligations with DCWP or with outside counsel. The workbooks that support this cycle document your rationale and track dates — they don't perform, certify, or sign a bias audit, and they never score any individual candidate or employee. That's the job of the independent auditor you engage separately.

Building a renewal cycle instead of a scramble

A working AEDT annual bias audit expiry and renewal cycle has a rhythm, not just a deadline:

• A living register of every active AEDT with its last audit date and calculated expiry date, reviewed at fixed intervals — not just when someone remembers.
• 90/60/30-day internal check-ins before each expiry, escalating from "start scheduling the auditor" to "confirm the summary is drafted and ready to post."
• A change-trigger checklist reviewed any time a vendor announces a model update, you switch AEDT vendors, or you extend a tool into a new decision point — feeding back into the same expiry calculation.
• A separate lane from general vendor procurement, so an IT contract renewal doesn't quietly absorb or obscure the audit-currency question.

If you're mapping this against a full-year filing rhythm, the Local Law 144 compliance deadline calendar lays out how audit renewal sits alongside notice and posting deadlines across the year, and the NYC Local Law 144 compliance guide is the right starting point if any of the underlying obligations above are still new to your team.

Where the workbook fits — first action item

The fastest way to stop guessing at audit-currency status is to put the register above into a structure built for exactly this job. The Annual Re-Verification & Audit-Expiry Renewal Planner is a downloadable workbook built to track expiry dates, flag upcoming renewals, and log the change-trigger events that can force an early re-audit — one row per AEDT, one clock per tool, no more folder archaeology.

Download it, load your current AEDT inventory and last-audit dates into it this week, and you'll have a real answer the next time someone asks whether you're covered — today, not last spring.