Clarify whether LL 144 penalties apply per candidate or per audit

Clarify whether the civil penalties prescribed by New York City Local Law 144 for violations related to automated employment decision tools are assessed on a per-candidate basis or on a per-audit basis, in order to resolve enforcement ambiguity and quantify potential liability.

Background

Local Law 144 authorizes the Department of Consumer and Worker Protection to assess civil penalties for violations. The text references fines per day, but an auditor’s observation reported by the authors notes ambiguity about whether penalties attach per candidate or per audit, implying significantly different cost exposures and enforcement dynamics.

Resolving this uncertainty is necessary for consistent enforcement and for employers and auditors to understand compliance risk and remediation priorities.