Preparing for NYC Automated Employment Decision Tool Law

The Resolution Economics AI Audit Team submitted a second round of Comments in response to NYC’s Department of Consumer and Worker Protection (“DCWP”)’s revised set of proposed rules for the new Automated Employment Decision Tools (“AEDT”) law, a law that requires that such tools undergo a bias audit. We were pleased that the DCWP made some adjustments to the initial proposed rules for the bias audits following our first set of Comments in October 2022. Based on our Team’s experience conducting bias audits for clients and its thought leadership in this space [View Institute for Workplace Equality Technical Advisory Committee AI Report] our second set of Comments urged further rule clarifications to enhance compliance. The DCWP has indicated it will begin enforcement of the new law beginning April 15, 2023.