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AI in hiring: NYC Local Law 144, Illinois, Colorado and the EU AI Act

AI hiring tools carry the most specific rules on record: NYC bias audits and notices, Illinois, Ontario job postings, Colorado from 2027 and the EU AI Act high-risk regime.

  1. Inventory the tools

    List every tool that screens, ranks, scores or recommends candidates or employees, who supplies it, and where the candidates are. The rules attach to where the job or the person is, not where the employer is.

  2. New York City: bias audit and notice

    Under Local Law 144, enforced since 5 July 2023, an employer or agency using an automated employment decision tool for a NYC job must have an independent bias audit within the year before use, publish a summary of the results, notify candidates beforehand, let them ask for an alternative process or accommodation, and disclose the data collected and its retention policy.

  3. Illinois

    Illinois HB 3773, effective 1 January 2026, makes it a civil-rights violation to use AI in recruitment, hiring, promotion, discipline or discharge in a way that discriminates on a protected basis, or to use zip codes as a proxy; employers must notify employees when AI is used for such decisions. The AI Video Interview Act has applied to AI analysis of video interviews since 2020.

  4. Ontario job postings

    Ontario requires employers with 25 or more employees to state in every publicly advertised job posting whether AI is used to screen, assess or select applicants, from 1 January 2026.

  5. Colorado from 2027

    Employment is a consequential-decision area under Colorado SB 26-189, applying from 1 January 2027 (record pending review): advance notice, adverse-decision disclosure with the principal reasons, human review, and three-year records.

  6. EU AI Act

    AI used in employment and worker management is among the high-risk uses listed in Annex III. With the Omnibus, those duties apply from 2 December 2027 (record pending review). Employers must also inform workers and their representatives before using a high-risk system at work.

  7. One evidence pack

    Keep, per tool: the vendor's documentation, a selection-rate and impact-ratio analysis, the candidate notice, the alternative-process route, the human-review procedure and the decision records. The employment bias audit kit template holds all of these.

Obligations referenced in this guide

Frequently asked questions

Do I need a bias audit for an AI hiring tool?

For jobs in New York City, yes: Local Law 144 requires an independent bias audit within the year before use, and a published summary. Other laws on record ask for notice, non-discrimination and records rather than a formal audit.

Must I tell candidates that AI is used?

Under several laws on record, yes: NYC Local Law 144 (before use), Illinois HB 3773, Ontario job postings and, from 2027, Colorado SB 26-189. The EU AI Act requires informing workers and their representatives.

Does Local Law 144 apply outside New York City?

It applies to the use of automated employment decision tools for jobs and candidates in New York City, wherever the employer is based.

Is AI recruiting software high-risk under the EU AI Act?

Yes. Employment uses are listed in Annex III, so the high-risk duties apply, from 2 December 2027 after the Omnibus according to the record.

Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.