Short answer. On December 2, 2025, the New York State Comptroller published an audit of DCWP's LL144 enforcement system covering July 2023 through June 2025. DCWP had reviewed websites and bias audits associated with 32 companies. State auditors reviewed the same population and reported at least 17 instances of potential non-compliance that DCWP had not identified.
This was a compliance review, not “32 fines”
The official report says DCWP reviewed company websites, transparency notices and applicable bias-audit materials. AUDITLL144 does not describe those 32 reviews as 32 inspections or 32 enforcement penalties. Potential non-compliance is also not the same thing as an adjudicated violation or a civil fine.
What DCWP reviewed
The Comptroller report states that the 32-company population included 22 employers and 10 AEDT vendors. For each company, DCWP reviewed whether:
- the bias auditor was independent;
- the bias audit included selection-rate and impact-ratio calculations;
- the audit used historical data;
- the company had a bias audit clearly and conspicuously posted; and
- the bias audit was completed within one year.
Where the State auditors found additional issues
| Potential issue category | DCWP count | State auditor count |
|---|---|---|
| Bias audit not conducted by an independent auditor | 1 | 3 |
| Selection-rate / impact-ratio calculations not properly included | 0 | 5 |
| Use of historical data not properly explained | 0 | 9 |
The report cautions that these were potential compliance issues identified from the available materials. DCWP's response also disputed or qualified aspects of the auditors' analysis and stated that some issues would require deeper investigation of individual companies.
Why this matters operationally
The audit shows that public-facing compliance evidence itself can become part of regulatory review. Independence, calculation completeness, historical-data explanations, publication and audit recency are not merely drafting details; they were among the controls reviewed by government auditors.
Demand letters were documented
The report states that DCWP sent demand letters to two employers concerning the posting requirement and asked them to provide evidence of compliance. This is verified regulatory activity, but it should not be described as a civil penalty unless a source documents an imposed penalty.