Enforcement tightened in 2026 after the State Comptroller audit of DCWP. Book a free 20-minute scoping call →
Greenpoint
Reference

AI hiring and employment laws by jurisdiction

A working reference for employers trying to work out which algorithmic accountability regimes actually reach them. Updated as regimes take effect or change status.

Updated August 2026 · verify current status before relying on any entry

The single most useful thing to understand: most of these regimes attach based on where the candidate is, not where the company is. A remote-first employer in one state can be simultaneously covered by several. Headquarters location is rarely the answer.

Regimes in force

Scroll table sideways →

JurisdictionInstrumentStatusCore obligationWho it reaches
New York CityLocal Law 144 of 2021In force Annual independent bias audit, published summary, 10-business-day candidate notice with opt-out Employers using AEDTs for candidates or employees located in NYC — regardless of employer location
IllinoisHB 3773 (amending IHRA)In force Prohibits AI use that produces discriminatory effect; notice required when AI is used in covered decisions Illinois employers, broader decision scope than NYC — covers recruitment, promotion, discipline, discharge
TexasTRAIGAIn force Jan 2026 Intent-based prohibitions on discriminatory AI development and deployment Broader than employment; a general AI governance statute
CaliforniaSB 53In force Jan 2026 Frontier model transparency and safety reporting Developers rather than employers — relevant if you build rather than buy
European UnionEU AI ActEnforcement Aug 2026 Employment AI is Annex III high-risk: conformity assessment, technical documentation, logging, human oversight Providers and deployers placing systems on the EU market or affecting EU persons

Uncertain or delayed

Scroll table sideways →

JurisdictionInstrumentStatusWhat it would require
ColoradoSB 24-205Delayed & contested Impact assessments and algorithmic discrimination duties for high-risk systems. Originally effective February 2026, amended August 2025, pushed to 30 June 2026, with its future genuinely uncertain. Notably references ISO/IEC 42001 as a recognized risk management framework, which may function as a safe harbor.
New JerseyA 3854Pending An AEDT bias audit regime modeled on the NYC approach
FederalDecember 2025 preemption orderLitigated DOJ is challenging state AI laws under a preemption theory. This does not currently relieve anyone of compliance obligations, but it makes multi-year planning genuinely difficult.

The regimes that already applied

Something employers routinely miss: algorithmic hiring was never unregulated. Title VII, the ADA, the ADEA, the NYC Human Rights Law and the New York State Human Rights Law all reached discriminatory selection procedures long before any of the statutes above existed, and the EEOC's Uniform Guidelines have set out adverse impact methodology since 1978.

The practical consequence is worth stating plainly. A failing impact ratio is generally not itself a violation of Local Law 144 — the statute requires you to calculate and publish, not to pass. But that same failing ratio is squarely relevant under Title VII and the city and state human rights laws, where the exposure is class litigation rather than a per-day penalty. The disclosure regimes are, in effect, a discovery mechanism for the discrimination regimes.

A practical sequence

  1. Map your candidate geography. Where do applicants actually live? For remote roles this is the determinative fact and most companies have never asked it.
  2. Inventory the tools. Applicant tracking systems, resume parsers, assessment platforms, scheduling tools with knockout logic, recruitment marketing. Exposure hides in systems people assume are manual.
  3. Apply each definition in writing. The definitions differ — NYC's "substantially assist" test is narrower than Illinois's decision scope.
  4. Run the math before you are required to. Knowing your impact ratios before an audit compels publication is worth a great deal. Use the calculator.
  5. Build the recurring process. NYC's audit expires annually. This is a program, not a project.

This reference is general information about regulatory requirements and is not legal advice. Statutory status changes frequently, particularly in this area — verify current status and consult employment counsel before relying on any entry.

Not sure which of these reach you?

Coverage usually turns on where your candidates live and what your tools actually do. Twenty minutes on a call generally settles it.

hello@greenpointcompliance.com