Building a Local Law 144 Compliance Deadline Calendar

When the Annual Audit Quietly Expires

Nobody misses a Local Law 144 deadline on purpose. It happens because the audit that ran clean last spring becomes background noise by fall, the person who tracked it changes roles, and the spreadsheet tab with the date in it stops getting opened. Then a recruiter flags a new AEDT rollout, someone asks "wait, when was our last audit," and the honest answer is a shrug.

That's the actual failure mode behind Local Law 144 non-compliance — not ignorance of the law, but a deadline that nobody was watching. The New York City Comptroller's own 2025 review of enforcement found this pattern at scale: audits that should have been current weren't, and the agency built to catch that wasn't catching it either. If the regulator's tracking has gaps, an HR team running this off memory and a shared drive doesn't stand a better chance.

A Local Law 144 compliance deadline calendar fixes the specific failure — not "we didn't know the rule," but "we knew it and it lapsed anyway." By the end of this piece, you'll know exactly which recurring dates belong on that calendar, in what order, and how to build one that surfaces the next perishable deadline before it becomes a violation.

What Local Law 144 Actually Requires, and How Often

Local Law 144 took effect January 1, 2023, with enforcement starting July 5, 2023, after a delay from an originally announced April 15 date (per Epstein Becker Green's 2023 tracking of the rollout). It imposes three recurring obligations on employers using an automated employment decision tool — an AEDT, defined broadly as any computational process built on machine learning, statistical modeling, or data analytics that issues a score, classification, or recommendation used to substantially assist or replace a hiring or promotion decision (Perkins Coie, 2023).

The three obligations, and their cadence:

1. An independent bias audit, conducted annually. Not once at launch — every year the tool stays in use.
2. A public summary of the most recent audit results, posted on the employer's website, along with the date the AEDT was first used and the distribution date of the audit (Crowell & Moring LLP, 2023).
3. Candidate and employee notice at least 10 business days before the AEDT is used, including a path to request an alternative process or accommodation (Epstein Becker Green, 2023).

Every one of those is date-bound and recurring, which is exactly why a static checklist doesn't hold up. A checklist tells you what to do once. A calendar tells you when to do it again — and again, on a rolling basis, for as long as the tool stays deployed. If you're still mapping out the full obligation set before you build the calendar around it, our guide on the Local Law 144 requirements walks through each one in more depth.

Why Spreadsheets Don't Remind Anyone

A spreadsheet is a record. It is not an alarm. That distinction is the whole problem.

The Comptroller's audit covered the period from July 2023 through June 2025 and concluded the city's own enforcement was ineffective — DCWP's review found only 1 of 32 sampled companies non-compliant, while the Comptroller's auditors, looking at the same 32 companies, found 17 (Office of the NY State Comptroller, 2025). That's not a small tracking gap; it's most of the sample. Separately, a 2024 academic study of 391 employers subject to the law — the "Null Compliance" study — found only 18 had posted an audit report and only 13 had posted the required transparency notice (ACM FAccT, Wright & Muenster et al., 2024). Those aren't employers who never intended to comply. Most likely intended to, and the deadline slipped past them anyway.

The civil penalty structure makes the cost of that slippage concrete. Violations can run up to $500 for a first offense, $500 to $1,500 for each subsequent one, and — this is the part that matters for a calendar — penalties accrue per violation, per day (Office of the NY State Comptroller, 2025). A missed renewal isn't a one-time fine. It's a fine that compounds for every day the audit stays lapsed and the AEDT stays in use.

A calendar built around these dates does one job a spreadsheet doesn't: it forces someone to look at the next deadline before it's the deadline that already passed.

Building a Local Law 144 Compliance Deadline Calendar

Start with the anchor date: the day your current bias audit was distributed. Everything else on the calendar is calculated relative to that one date, which is why getting it right matters more than any other entry.

From that anchor, a working Local Law 144 compliance deadline calendar needs at minimum:

• Audit renewal window — the annual bias audit doesn't have a single statutory number of days like the notice period does; it needs to be current for as long as the AEDT is deployed. Build your internal renewal target with margin — most teams working from a documented rationale set the internal target 60–90 days ahead of the anniversary of the last audit, so there's runway to book the independent auditor, receive results, and post the summary before anything goes stale. Confirm your own vendor's specific audit cadence and any AEDT-specific renewal triggers directly with DCWP or your auditor, since deployment changes can shift the clock.
• Public posting deadline — the date the audit summary needs to be live on your website, tied to the audit distribution date.
• Candidate/employee notice lead time — 10 business days before each use of the AEDT, recalculated every time a new hiring cycle, role, or location brings the tool back into play.
• Vendor audit-status check-ins — quarterly touchpoints to confirm the AEDT vendor's own audit status hasn't lapsed on their end, independent of your renewal.
• New-tool intake trigger — any time a new AEDT enters use, it starts its own version of this entire cycle from day one.

If you're unsure how the annual renewal interacts with a tool you deployed mid-year, our piece on how often a bias audit is required in NYC and the companion on AEDT annual bias audit expiry and renewal both walk through the timing math in detail — worth reading before you lock your first calendar entries.

What Belongs on the Calendar Beyond the Audit Date

The audit date gets the attention, but it isn't the only perishable item. A calendar that only tracks the audit and skips everything downstream of it will still let a violation through.

Add these recurring checkpoints:

• Website posting audit — a periodic check that the public summary is still live, still current, and still shows the right distribution date. Postings quietly disappear during site redesigns more often than teams expect.
• Notice template refresh — a review of the candidate notice language whenever the AEDT's function changes, so the "alternative process" pathway described in the notice still matches reality.
• Four-fifths rule spot-check — not a substitute for the independent audit, but an internal sanity check using the EEOC's four-fifths guideline (a selection rate for any group under 80% of the highest-selected group's rate may indicate adverse impact, per the Uniform Guidelines) so surprises surface before the annual audit does, not during it.
• Documentation retention — a scheduled point to archive last year's audit report and notice records before they're overwritten, since the calendar needs a paper trail as much as a due date.

None of this is a substitute for the independent bias audit itself, and none of it is legal advice — it's the operational scaffolding that keeps the recurring obligations from becoming a surprise. If a filing deadline or a notice question comes up that turns on a legal determination, that's a conversation for DCWP or outside counsel, not a calendar entry.

Operations, Not Legal Advice

Worth stating plainly: nothing in a compliance calendar performs, certifies, or signs a bias audit, and nothing in it scores any individual candidate or employee. The calendar's job is to make sure the actual audit — the one your independent auditor performs — happens on schedule, gets posted where it's supposed to be posted, and gets renewed before it lapses. The audit itself still has to come from an auditor with no financial or employment relationship to you or your AEDT vendor, exactly as the law requires. A calendar organizes the operation around that audit. It doesn't replace it, and it isn't legal counsel on whether a specific tool qualifies as an AEDT in the first place — confirm that with DCWP or your own counsel when there's ambiguity.

Your First Action Item

Right now, this has to run on a calendar you build and maintain yourself — there's no live reminder system watching these dates for you today. That kind of always-on reminder engine, along with a hosted vendor audit-status lookup, is something we're building toward; if that's useful to you, the waitlist is the place to say so.

Until then, the fastest way to get every recurring Local Law 144 date — audit renewal, posting deadline, notice lead time, vendor check-in — into one place is to start from a structure that already has them mapped out. The LL144 + WARN Compliance Calendar & Filing Tracker is built exactly for that: a downloadable workbook that lays out the recurring dates so you're filling in your specific anchor dates, not designing the calendar from scratch. If you want the full obligation checklist first, our Local Law 144 compliance guide is the place to start, and once your calendar's running, the annual bias audit renewal reminder piece covers what to do in the weeks before each renewal comes due.