A Local Law 144 bias audit examines an automated employment decision tool for disparate impact across sex, race and ethnicity, and the employer publishes a summary of the results. The auditor needs more than the tool's scores: they need to establish which tool was used, on which candidate pool, over what period, and what a named human did with the output. That last part is where the record usually stops, because nobody wrote it down at the time.
The text of the obligation is summarised at NYC Local Law 144, automated hiring bias audit.
Three records an auditor asks for, and which one is usually missing
The tool's own output
Scores, rankings or classifications produced by the automated tool. Vendors generally supply this, and it is the part employers expect to be asked for.
The candidate data
The pool the tool was run against, with the demographic categories the audit needs. Sensitive, but usually retrievable from the applicant tracking system.
The human decision record
Who looked at the output, what they considered, and what they decided. This is the one that is rarely written at the time, and it is the one that shows whether the tool substantially assisted the decision or merely informed it.
Why the human record matters more than it looks
The scope of the obligation turns on how the tool was used. A tool that substantially assists or replaces discretionary decision making is in scope; one input among many, weighed by a person, may sit differently. That distinction is a question of fact about what the human actually did.
If the only evidence is the tool's log, the answer is whatever the log implies. If a named recruiter recorded at the time what they reviewed and what they decided, the answer is on the record in their own words. Reconstructing it a year later, from memory, in front of an auditor, is the position nobody wants.
What a defensible entry carries
| Field | What it establishes |
|---|---|
| which tool, for what | The tool used and the purpose, declared by the person who used it rather than inferred from a vendor log. |
| who reviewed | A named person the entry is attributable to. An entry nobody signed is an entry nobody owns. |
| what was considered | The specific checks and factors that person applied to the output, in their words. |
| which decision | Fingerprints binding the entry to the exact document or record produced, so it cannot drift onto another candidate. |
| when, and on whose clock | The time, marked self-asserted or witnessed, so the auditor knows how much the timestamp is worth. |
A Regulayer Receipt carries those fields, sealed on the reviewer's own machine at the moment of review, and anyone can verify it free without seeing the candidate data. The format is set out at the Regulayer Receipt.
Notice, publication and the annual cycle
The obligation runs on a yearly rhythm: an independent audit within the preceding period, a published summary, and notice to candidates before use. The evidence, though, accumulates daily. An employer who starts collecting the human record when the auditor calls has a year of hiring decisions with nothing behind them.
Keeping the record at the point of use turns the annual audit into a retrieval exercise rather than a reconstruction. Where the rules change in the meantime, when the law changes covers how existing records are read against a later standard.
The limits
Tamper-evident, not tamper-proof. Nothing is unalterable. The guarantee is narrower and stronger: any change after sealing breaks the signature, and the break shows on verification.
It records evidence. It does not certify compliance. A bias audit is performed by an independent auditor against the tool and the data. A record of human review is evidence the auditor can use; it is not the audit, and it does not certify that the tool or the process complies.
Attested, not proved. A signature makes a declaration permanent and attributable. It does not make it true. The record says a named person declared this, at this time, and nothing has changed since. That is what it shows, and it is all it shows.
Questions people ask
Does a receipt satisfy Local Law 144?
No. The law calls for an independent bias audit, published results and candidate notice. A receipt is evidence of the human review around a tool, which the auditor can examine. It is one input to the audit, not a substitute for it.
We use a vendor tool. Whose record is this?
Both. The vendor holds the tool's behaviour; you hold what your people did with the output. The second is the part an auditor cannot obtain from the vendor, and the part that establishes how the tool was actually used in your process.
Does the record contain candidate data?
No. It carries fingerprints of the file rather than the file, so it can be produced to an auditor without disclosing the candidate pool or the underlying assessment.
What if the review happened but was never written down?
Then it is testimony rather than a record, and its weight is whatever the reader gives it. The point of sealing at the time is that the declaration is fixed, attributable and checkable later by anyone.
Record the human review while the hiring decision is being made.
The live demos sign a real record in your browser and let you alter it: change one character and verification flips to tampered. Seven days free, then $349 a month. Cancel at any time; records already signed stay independently verifiable.
Written 16 August 2026. A summary for orientation, not legal advice. A receipt attests what the signer declared; it does not certify compliance with Local Law 144, and the audit itself is performed by an independent auditor.