Null Compliance is Not Non-Compliance in NYC's Algorithm Audits

This examines the initial implementation and effectiveness of New York City's Local Law 144 (LL 144), a landmark regulation mandating bias audits for Automated Employment Decision Tools (AEDTs) used in hiring and promotion. The authors, a group of university researchers and student investigators, report remarkably low rates of compliance with the law's requirements for posting public audit reports and transparency notices. A central finding is the concept of "null compliance," which describes the inability to determine non-compliance due to the significant discretion granted to employers over whether their systems fall within the law's scope. Furthermore, the study critiques the law for creating a confusing user experience for job seekers and for failing to establish a clear floor for acceptable discrimination rates, potentially encouraging employers to withhold unfavorable audit results to avoid litigation risk. Ultimately, the paper concludes that the law's design hinders transparency, making it impossible to assess whether LL 144 is achieving its goal of reducing employment discrimination.

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