Short answer: the clearest public evidence on NYC Local Law 144 enforcement in 2026 remains the New York State Comptroller's December 2025 audit of DCWP's enforcement system. The audit found weaknesses in complaint routing and in DCWP's review of public bias-audit materials, while distinguishing potential non-compliance from adjudicated violations.
| Verified finding | What it means |
|---|---|
| Only two AEDT complaints were received during the audit scope | Low complaint volume does not establish broad compliance. |
| DCWP reviewed 32 companies and identified one issue of non-compliance | DCWP had an active review process, but OSC found gaps in how requirements were tested. |
| OSC identified at least 17 instances of potential non-compliance in the same sample | These were oversight findings, not automatically adjudicated violations. |
What did the State Comptroller review?
The Office of the New York State Comptroller (OSC) assessed whether DCWP had designed and implemented an effective system to enforce Local Law 144.
What did the audit find about complaints?
OSC reported that DCWP had received only two AEDT complaints during the audit scope and found weaknesses in complaint routing. In OSC's test calls to 311, only three of twelve calls were correctly transferred to DCWP.
What did the audit find about website and bias-audit reviews?
According to OSC, DCWP reviewed websites and bias audits for 32 companies and identified a single issue of non-compliance. OSC reviewed the same companies and identified at least 17 instances of potential non-compliance.
This does not mean that every potential issue identified by OSC became an adjudicated violation. It does show that audit/publication review can fail when the review process does not systematically test all relevant requirements.
What did OSC recommend for stronger enforcement?
Among its recommendations, OSC called for better complaint handling, more complete bias-audit reviews, use of available technical expertise, and mechanisms to identify potential non-compliance through research and other leads in addition to complaints.
What does DCWP publicly provide now?
DCWP's official AEDT page continues to provide the law/rule, FAQ and complaint mechanism. It tells users they can report use of an AEDT where the required audit, public summary or notices were not provided.
What does this mean for employers and AEDT vendors?
- Do not assume low complaint volume means the rule can be ignored.
- Do not treat a public-summary page as evidence that the underlying audit is methodologically sound.
- Preserve source data, calculation evidence and review records.
- Verify publication content against 6 RCNY §5-303 rather than copying a competitor's summary.
- Track the one-year audit cycle and the six-month post-use publication period.
What does the Comptroller report not prove?
OSC's findings are oversight findings, not a substitute for DCWP adjudication in an individual case. The report also records areas where DCWP disagreed with some findings. A responsible 2026 enforcement page should distinguish those facts rather than predicting a particular employer's enforcement outcome.
Primary sources: NY State Comptroller — Enforcement of Local Law 144 · NYC DCWP AEDT page · 6 RCNY §5-303.
Related: Penalty framework · Audit methodology.
Start by checking whether LL144 may apply to the workflow, then confirm data readiness before requesting an independent audit.
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Open the enforcement & oversight tracker · Review the audit evidence package
General information only; not legal advice.