Who Can Perform a Local Law 144 Bias Audit?

When the Audit Deadline Is Two Weeks Out and You're Still Vendor-Shopping

You've got a resume-screening AEDT live on your careers page, an audit deadline circled on the calendar, and three quotes sitting in your inbox from firms that all say the same thing: "We handle Local Law 144." One of them also happens to be the company that sold you the applicant tracking system your AEDT plugs into. Another is a governance dashboard that promises to "manage your compliance" but won't say, in writing, who actually signs the audit report. The third looks legitimate but you have no way to check.

This is the moment most HR Directors realize the law doesn't just require an audit — it requires the audit come from someone specific, and getting that wrong can invalidate the whole exercise. By the end of this piece, you'll know exactly which vendors are structurally eligible to sign your bias audit, which ones are disqualified before they ever open a laptop, and how to scope an engagement so the question never comes up again.

Who Can Perform a Local Law 144 Bias Audit, and Who's Disqualified

The short answer to who can perform a Local Law 144 bias audit is: an auditor with no financial or employment relationship to you, the employer, or to the company that built the AEDT you're using. That's the entire eligibility test, and it's narrower than most first-time buyers assume.

Local Law 144 sets out three core obligations for employers using an AEDT to screen or evaluate NYC candidates or employees: 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 advance notice to candidates and employees — at least 10 business days before use — with an alternative-process or accommodation option (Crowell & Moring LLP, 2023; Epstein Becker Green, 2023). The audit obligation is the one that trips up buyers first, because "independent" is doing real legal work in that sentence. It's not a marketing adjective. It's a disqualifying test.

If you're asking who can perform a Local Law 144 bias audit for your organization specifically, start by ruling people out, not in. Anyone on your payroll is out. Anyone the AEDT vendor pays, or who pays the AEDT vendor, is out. Anyone whose fee depends on the audit result — a bonus for a clean report, a penalty for a flagged one — is out. What's left is a narrower field of firms whose entire business model is arm's-length assurance work.

The Independence Bar: No Financial or Employment Relationship

The independence requirement exists because a bias audit that grades its own author isn't an audit — it's a press release. Local Law 144 requires that the auditor have no financial or employment relationship to the employer or to the AEDT vendor whose tool is under review (Crowell & Moring LLP, 2023). That single line rules out several categories of vendor that look, on the surface, like reasonable candidates:

• The AEDT vendor itself, or any subsidiary of it, offering to "self-certify" its own tool.
• A consulting firm that also holds a paid implementation or support contract with the AEDT vendor.
• A platform whose revenue model depends on selling you the same company's compliance software and its audit sign-off.

This is also the structural reason a vendor that sells you audit-documentation tooling — trackers, registers, notice templates — cannot, at the same time, sell you the actual bias audit sign-off for that same AEDT. The two roles sit on opposite sides of the independence line by design. Our own independent bias auditor under Local Law 144 breakdown goes deeper into what qualifies a firm to sign, and our piece on bias auditor conflict of interest and independence walks through the specific relationships that disqualify a candidate auditor before you sign an engagement letter.

Auditor vs. Platform: A Structural Distinction, Not a Marketing One

Here's where buyers get confused, and it's not their fault — the marketing language across this space is genuinely blurry. Some companies are independent auditors: their business is performing the audit itself, and their fee structure is built around the annual audit cycle. Others are general AI-governance platforms: software that helps a company track policies, risks, and controls across many regulatory frameworks, but that does not itself perform the LL144 bias audit as an independent third party.

BABL AI is an example of the first category — an independent third-party auditor that performs LL144 bias audits under the ISAE 3000 assurance standard, which is an audit-execution role (BABL AI, 2025). Warden AI similarly positions itself as an independent, continuous bias-auditing platform for HR-tech vendors and employers, also operating on the audit-execution side, with its work spanning LL144 alongside frameworks like the EU AI Act. Note that vendor framework lists date quickly — Colorado's SB 24-205, which several vendors marketed against, was repealed and replaced on 14 May 2026 by SB 26-189, the Automated Decision-Making Technology Act — a narrower disclosure regime that drops the impact-assessment and duty-of-care requirements entirely and takes effect 1 January 2027. Neither publishes a public price list — both operate on custom or flat-fee engagement terms tied to the scope of the audit, which is standard for this kind of assurance work.

Contrast that with a broad AI-governance platform aligned to frameworks like ISO 42001 or NIST AI RMF. That kind of tool can be genuinely useful for tracking controls across many jurisdictions, but it is not built specifically around the NY statute, and using one doesn't answer the question of who can perform a Local Law 144 bias audit for you — it answers a different question about internal governance tracking. Our comparison of a bias audit platform vs. an independent auditor lays the two categories side by side so you're not guessing which one you're actually buying.

The independence test isn't about which vendor has the nicest dashboard. It's about who has zero financial stake in the answer.

What an Eligible Auditor Actually Delivers

An eligible auditor's output isn't a certificate — it's a written assessment of your AEDT's selection or scoring outcomes across demographic categories, measured against a recognized statistical benchmark. The common reference point is the four-fifths (80%) rule: a selection rate for any group that falls below 80% of the rate for the highest-selected group may indicate adverse impact under the EEOC's Uniform Guidelines framework (via Assessment Systems, 2024). The auditor calculates that ratio from your actual usage data, documents the methodology, and produces results that get summarized publicly on your website along with the AEDT's distribution date.

What an eligible auditor does not do is tell you whether you're legally compliant overall, or give you legal advice about your specific exposure. That determination sits with your own counsel. This is operational and audit guidance, not a legal opinion — treat everything here as a starting point for a conversation with DCWP or outside counsel, not a substitute for one.

It's also worth being blunt about enforcement reality: a December 2025 Comptroller's audit covering July 2023 through June 2025 found the city's enforcement of LL144 "ineffective," with the Comptroller's own auditors identifying 17 non-compliant companies out of a 32-company sample where DCWP's process had flagged far fewer (OSC, 2025). Separately, a 2024 academic study of 391 employers found only 18 had posted audit reports and only 13 had posted transparency notices (ACM FAccT, Wright & Muenster et al., 2024). None of that changes who can perform a Local Law 144 bias audit — it changes how much weight you should put on "everyone else is doing it this way" as a defense. Weak enforcement today doesn't reduce your exposure if enforcement tightens tomorrow.

Building Your Auditor Shortlist Without Guessing

Once you've filtered out anyone with a financial or employment tie to you or your AEDT vendor, the practical shortlist process looks like this:

1. Ask directly, in writing, about financial relationships. Any hesitation to answer is itself an answer.
2. Confirm the audit methodology in advance — how they calculate selection rates, what demographic categories they use, and how they handle missing data (a known weak point flagged by the 2025 "Auditing the Audits" study, which found many published LL144 audits may under-report disparities due to incomplete demographic data and opaque aggregation methods (ACM FAccT, 2025)).
3. Get the engagement scope in writing before the audit starts, not after — including timeline, deliverables, and who owns the public summary language.
4. Separate the audit engagement from any documentation or tracking tooling you buy. Keeping those two purchases with two different, unaffiliated parties is what keeps your audit itself unquestionably independent.

Our independent auditor engagement scope for Local Law 144 piece walks through what a proper scoping conversation covers line by line, and our NYC Local Law 144 compliance guide is the right starting point if you're still mapping out the full set of obligations around the audit itself.

Your First Move: Scope the Engagement Before You Call Anyone

You don't need to have this conversation from scratch with every vendor that emails you. The Independent-Auditor Engagement RFP & Scoping Kit gives you the questions to ask, the independence disclosures to request in writing, and a scope-of-work structure you can hand to any candidate auditor before you sign anything — so the eligibility question gets answered on paper, not in a follow-up email six weeks later.

To be clear about what this kit is and isn't: it's a documentation and RFP-scoping tool that helps you run the vendor-selection process. It does not perform, certify, or sign a bias audit, and it won't score any individual candidate or employee — that work stays with the independent auditor you engage. Think of it as the operational scaffolding around a decision your legal and compliance team still needs to make with real diligence. Download the kit and start your shortlist with the independence question already answered.