NYC Local Law 144 and NODES: what an AEDT deployment looks like when it is built for the audit.

What Local Law 144 requires

The law covers automated employment decision tools, AEDTs, used on candidates for jobs in New York City. For a covered tool, the law imposes three obligations on the employer that uses it.

• An independent bias audit of the tool, repeated every year. The audit measures selection rates and scoring rates by category.
• Published results. The audit findings are posted publicly, so candidates and regulators can read them.
• Candidate notice. Candidates are told that the tool will be used in the decision.

The independence requirement is the one that shapes everything else. The vendor of the tool cannot audit its own system. The employer commissions an outside auditor, and that auditor needs real data to work from.

How NODES supports each obligation

NODES is the tool vendor. Its job is to make the audit possible, the notice routine, and every decision reviewable.

• Audit data. Selection-rate and scoring-rate data by category exports from the deployment’s own production records, formatted for the independent auditor. The auditor works from the same records the employer sees, not from a sample the vendor prepares.
• Candidate notice. Notice templates ship with the deployment, ready for the employer’s counsel to adapt and route through the existing candidate touchpoints.
• Audit substrate. Every score carries a Decision Trace, a signed and reproducible record of what the model read and how it reached the score. Traces stay reproducible for 7 years, customer-adjustable, so a past decision can be re-examined against the original record.
• Human review on every decision. No candidate is advanced or rejected on the AI score alone. A person at the employer reviews and decides, and that review is part of the record.

What NODES does not do

NODES does not perform the independent bias audit. The law requires independence, and NODES is the vendor of the tool. The employer chooses and engages the auditor.

NODES does not make legal determinations. Whether a specific deployment is covered by Local Law 144, what the candidate notice must say, and whether an audit result is acceptable are questions for the employer’s counsel.

Where to go next

The deployment controls an auditor reviews, along with the DPA, subprocessor list, and vulnerability disclosure policy, are on the Security & Compliance page. To walk through an audit-ready deployment, request a security review.