Clarify the extent to which LL 144 permits use of a vendor’s own audit

Clarify whether and to what extent independent auditors conducting an employer’s Local Law 144 bias audit may rely on, incorporate, or reference a vendor’s own audit when assessing the employer’s use of automated employment decision tools.

Background

Because Local Law 144 places obligations on employers rather than vendors, auditors often need vendor cooperation or data access. The paper notes that the law’s language leaves ambiguous whether an auditor may use or rely on a vendor’s own audit, even though pooled vendor data may be allowed under certain conditions.

This ambiguity affects audit methodology, data access strategies, and the comparability of audits across employers using the same vendor tools.