Publishing the Bias Audit Summary of Results on Your Website

The Audit Report Is Back. Now What Do You Post?

Your independent auditor just sent over the results. The resume screener your company has used since last spring came back with impact ratios that look fine, no red flags, nothing that needs a conversation with counsel. Relief lasts about ten minutes — then someone on your team asks the actual question: what goes on the website, and where?

This is the part of Local Law 144 that trips up a lot of otherwise-compliant employers. They commission the audit. They get the report. Then the report sits in a shared drive while the public-facing summary either never gets built or gets built once and never touched again. That's not a hypothetical — auditors reviewing hundreds of employer disclosures have found exactly this pattern at scale, and it's the single easiest violation for the city to spot without ever emailing you.

By the end of this piece, you'll know precisely what the summary of results needs to contain, where it needs to live on your site, and how to keep the date on it honest as your audit cycle renews.

What Local Law 144 Actually Requires You to Publish

Local Law 144 defines an automated employment decision tool, or AEDT, as any computational process derived from machine learning, statistical modeling, data analytics, or AI that issues a simplified output — a score, classification, or recommendation — used to substantially assist or replace discretionary decision-making in hiring or promotion (Perkins Coie, 2023). If your resume screener, video-interview scorer, or applicant ranker meets that definition and touches NYC-resident candidates or employees, three obligations follow: an annual independent bias audit, a public summary of the most recent audit results posted on your website, and advance notice to candidates and employees (Crowell & Moring LLP, 2023; Epstein Becker Green, 2023).

The publishing requirement is the one that's easiest to under-build, because the law is specific about what has to be public but says relatively little about layout or design. The summary of results needs to include the date the AEDT was distributed for use, and it needs to be posted on your website in a way a candidate could reasonably find it (Crowell & Moring LLP, 2023). It does not need to be the full audit report — the underlying methodology, raw data, and vendor detail generally stay internal — but the summary itself has to be public, current, and tied to the specific tool in use.

Enforcement took effect July 5, 2023, after a delay from an originally announced April 15, 2023 start date (Epstein Becker Green / Workforce Bulletin, 2023). That gap between the compliance obligation and the enforcement date is long gone. If you're deploying a covered AEDT on NYC candidates today, the posting clock is already running.

What Goes Into the Summary Itself

At minimum, a defensible summary of results states: the selection or scoring rates by category the audit examined, the impact ratios derived from those rates, and the distribution date of the tool being summarized. The four-fifths rule is the reference point most auditors use to flag a potential problem — a selection rate for any group below 80% of the rate for the highest-selected group may indicate adverse impact under the EEOC's Uniform Guidelines (via Assessment Systems, 2024). Your posted summary doesn't need to teach that formula to a job applicant, but the numbers on the page should be the numbers that formula was run against.

If you want a walkthrough of how to actually parse an audit report before you summarize it — what an impact ratio table is telling you, and what it isn't — that's covered separately in how to read a bias audit summary. It's worth reading before you draft anything for the public page, because a summary built by someone who misread the underlying report is worse than no summary at all.

One thing to be direct about: this is operational guidance, not legal advice. Whether your specific tool is covered, whether your specific summary format satisfies DCWP, and how to handle edge cases (a tool retired mid-year, a vendor swap) are legal-determination questions. Confirm those with DCWP or your own counsel before you publish. What follows here is the mechanics of running that publication process, not a substitute for that judgment call.

Where and How to Post It So It's Findable

"Posted on your website" is doing a lot of work in the statute, and enforcement reviews have shown employers interpret it loosely. A 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). That's not a close call — it's the overwhelming majority failing the most visible, least excusable part of the law.

Practically, that means:

• The summary lives somewhere a candidate would look — a careers page, an AI/AEDT disclosure page linked from careers, or a compliance/legal footer link that's actually discoverable, not buried three clicks deep in a privacy policy.
• The link is stable. If your careers site gets redesigned, the summary link is one of the things that has to survive the migration, not something that quietly 404s until someone notices.
• The summary is dated. A posting with no visible date next to the AEDT distribution date is functionally indistinguishable from a stale one — and a stale one is close to the same violation as no posting at all.

If you want the fuller mechanical rundown of the posting requirement specifically — format expectations, what "public" means in practice, how it interacts with multiple AEDTs in use at once — that's the focus of the AEDT bias audit posting requirement, and the broader statutory picture sits in Local Law 144's bias audit requirements and the full compliance guide.

Why the Date on the Page Matters More Than People Think

A recent independent review of enforcement found DCWP identified only a small number of non-compliant companies out of 32 examined, while the Comptroller's own auditors, reviewing the same companies, found roughly half non-compliant (OSC, 2025). That gap is the whole story of LL144 enforcement to date: on paper, most employers look fine; on closer inspection, a lot of them aren't. A stale summary — one still showing last year's distribution date, or one for a tool your vendor replaced — is exactly the kind of gap that looks fine until someone checks the date.

Separately, researchers examining published audits directly found that many understate real disparities because of missing demographic data, opaque aggregation, or metrics that don't reflect how the tool is actually deployed (ACM FAccT, "Auditing the Audits," 2025). That's a reason to take the underlying audit seriously, not just the posting — but it's also a reason to make sure your summary reflects the audit you actually have, not a template someone filled in once and forgot.

A summary of results that isn't dated to the tool currently in use isn't a compliant posting — it's a placeholder that happens to be public.

Keeping the Posting Attached to Your Audit Cycle, Not Detached From It

The failure mode isn't usually "we never posted anything." It's "we posted something once, correctly, and then the audit renewed the following year and nobody updated the page." Since the annual audit obligation repeats every year the AEDT stays in use, the summary has to repeat with it — same tool, new distribution date, new numbers if the audit produced them.

This is where most of the actual breakdown happens: not the drafting, but the tracking. Which AEDTs are live. When each one's audit is due. Whether the posted summary still matches the current audit. A compliance calendar built for LL144 and WARN together exists to hold exactly that tracking in one place — audit due dates, notice windows, and the posting-refresh checkpoint that keeps your summary from going stale between cycles. It doesn't perform the audit and it doesn't certify anything; it's the operational scaffolding that makes sure the audit you already commissioned actually shows up correctly, and on time, where a candidate can find it.

We're also building toward a hosted version of this tracking with automatic renewal reminders — not available today, but if that's useful to your team, join the waitlist to hear when it ships.

Your First Action Item

Pull up your careers site right now and find your current summary of results. Check the distribution date against the AEDT you're actually using this quarter. If the date is wrong, missing, or the page is more than one click from where a candidate would think to look, that's the fix to make this week — before the next audit cycle, not after it. Start with the LL144 + WARN Compliance Calendar & Filing Tracker to put the renewal date on a calendar you'll actually see.