NY State Comptroller Audit Finds DCWP's LL144 Enforcement Ineffective

In December 2025, the Office of the New York State Comptroller released an audit evaluating the NYC Department of Consumer and Worker Protection's (DCWP) enforcement of Local Law 144 (LL144), which regulates automated employment decision tools (AEDTs). The audit covered July 2023 through June 2025 and concluded that DCWP's enforcement system is ineffective.

Key Findings

Complaint intake failures: 75% of test calls to NYC 311 regarding AEDT issues were improperly routed and never reached DCWP
Superficial compliance reviews: DCWP reviewed 32 companies' bias audits and found only 1 issue; the Comptroller's own review of the same companies identified at least 17 potential violations
Unused enforcement procedures: DCWP failed to use the formal "Enforcement Workbook" or consult with the NYC Office of Technology and Innovation (OTI) when making determinations
Minimal complaints received: Only 2 AEDT complaints were received during the entire audit period
No proactive enforcement: DCWP does not routinely monitor compliance with annual bias audit requirements

DCWP's Response

DCWP committed to implementing most of the Comptroller's recommendations, including:

Strengthening complaint-handling processes to ensure AEDT complaints are properly routed
Providing cross-divisional training for staff
Implementing written policies for consistent handling
Enhancing enforcement through interviews and system demonstrations

What Employers Should Expect

With DCWP under public pressure to improve enforcement, employers using AEDTs should prepare for more rigorous oversight. Civil penalties can reach $500–$1,500 per day per violation. Employers should:

Conduct annual independent bias audits
Ensure audit summaries are publicly posted
Verify candidate notification compliance
Maintain compliance documentation