Verified against NYC Admin Code §§ 20-870–20-874 and the DCWP Final Rules. When the rule is ambiguous, we say so. When guidance is evolving, we mark it as such. No recycled commentary.
Three years after the compliance deadline, DCWP enforcement patterns, real-world compliance rates, and what triggers an investigation — with what the data does and does not tell us.
Read the pillar → Pillar · Dual complianceThe same recruitment algorithm often triggers two regulatory regimes at once. Where LL144 and EU AI Act Annex III overlap, where they diverge, and what a coordinated audit deliverable actually looks like.
Read the pillar → Note · DefinitionsThe "substantially assist or replace" threshold, the machine-learning requirement, and where vendors have tried to argue their product falls outside the rule.
Read → Note · IndependenceWhat the DCWP Final Rules actually disqualify, what counts as a "material indirect financial interest," and the documentation trail a defensible audit needs.
Read → Note · PenaltiesReading the penalty structure of NYC Admin Code § 20-872 literally — per violation, per day — and what that implies for cumulative exposure.
Read →LL144 + EU AI Act guidance