New York City does not currently have one general “NYC AI Act.” Local Law 144 remains a specific enacted regime for covered automated employment decision tools. The September 2026 Council package is broader, but the measures discussed below are legislative proposals and should not be treated as current compliance obligations.
What the Council announced
On September 25, 2026, Council Speaker Julie Menin announced a slate of AI proposals for Council-wide consideration. The package signals potential regulation of AI systems outside the employment context already addressed by Local Law 144.
Key proposals in the package
T2026-2602 — third-party validation and human shut-down capability. The proposal would restrict marketing, sale or deployment of an AI model in New York City without third-party validation and a human-operated shut-down capability. Validation topics include performance, disparate impact, privacy and safety.
T2026-2599 — chatbot privacy, security and transparency. The proposal includes data-use restrictions, user access to retained chat logs, disclosures that the user is interacting with a chatbot, and restrictions involving training, profiling and minors.
T2026-2600 — private cause of action. This proposal would allow claims for certain foreseeable harms caused by third-party misuse or malicious use where an AI provider failed to implement reasonable safeguards.
T2026-2601 — AI safety incidents in City contracts. Covered contractors and agencies would have 24-hour notification duties for reportable AI safety incidents, with public disclosure obligations for Cyber Command.
T2026-2603 — AI advertising. Advertisements promoting AI models would have to disclose third-party validation status and could not contain materially false or misleading safety claims.
T2026-2604 and T2026-2605 — whistleblowers and civilian enforcement. The proposals address protections for reporting certain AI risks and financial incentives tied to enforcement recoveries for specified AI violations.
T2026-2606 — AI emergency response. Cyber Command and NYC Emergency Management would develop and periodically update a response plan for defined AI-related emergencies affecting City systems, infrastructure, operations or public welfare.
How this differs from Local Law 144
Local Law 144 is already in force and targets covered AEDTs used in hiring and promotion. The new Council package is broader in subject matter and, as of this review, remains proposed legislation. An employer evaluating an AEDT should therefore continue to analyze LL144 separately rather than assume these proposals replace or amend its existing bias-audit, publication and notice requirements.
Why AI vendors should track this
If enacted, different bills could create controls around validation evidence, privacy, safety testing, incident response, human intervention and marketing claims. Those are separate legal questions from whether an employment tool is an AEDT under LL144.
NYC Council — September 25, 2026 AI legislative proposals
NYC Council Legistar — Committee of the Whole agenda
Related analysis
Third-party AI validation proposal · AI Oversight Office proposal · Current Local Law 144 guide