The proposal would require third-party validation before specified commercial activity or deployment in NYC, plus a technical capability allowing a human operator to shut down the AI model. The validator would certify validation status and disclose relevant interests.
What would validation examine?
The Council summary identifies task performance, disparate impact, data privacy and safety, including the functionality of the shut-down capability. The September 25 Council announcement also describes data quality, bias, decision outputs and security among the contemplated validation areas.
Is this another Local Law 144 bias audit?
No. LL144's enacted bias-audit framework is specific to covered automated employment decision tools and has defined calculations and publication requirements. T2026-2602 is a separate proposal addressing AI models more broadly. The two should not be conflated.
Conflict-of-interest and certification requirements
The proposal would require a validator to disclose interests relating to the AI model and to certify validation or deployment readiness to the developer and Cyber Command. The final scope could change during the legislative process.
Proposed penalties
The Council's September 25 announcement states that both the business and validator could face a $25,000 penalty for each instance involving an AI system marketed, offered for sale or deployed without required validation or where validation was falsified. Because the measure is not enacted, these are proposed penalties, not currently enforceable obligations.
What companies can do now
Companies can monitor the bill text and preserve evidence about model performance, risk testing, privacy, security, human oversight and validator independence. That is readiness planning, not a statement that T2026-2602 already applies.
Related resources
NYC AI legislative package overview · LL144 independent auditor requirements · LL144 audit methodology