Short answer. An employment agency using a qualifying AEDT to assess or screen candidates for a specific position can fall within Local Law 144. DCWP's FAQ also states that the location of the employment agency can be part of the “in the city” test.
Common agency workflows that require review
- Automated resume screening after application.
- Candidate scoring or ranking for client submission.
- Automated assessments used to decide who advances.
- Promotion-related screening performed for a client.
Sourcing is different from screening an applicant
DCWP distinguishes resume-bank searching, outreach and invitations to apply from screening a person who has applied for a specific position. The timing of when the tool is used therefore matters.
NYC nexus for agencies
DCWP's FAQ explains that covered use can arise when the agency using the AEDT is in NYC, or when the relevant job itself satisfies the NYC-office or NYC-associated remote-role conditions described by the agency.
Who is responsible if the client chooses the tool?
The factual allocation of responsibilities can vary, but the rule applies to employers and employment agencies that use covered AEDTs. A contract with a client or vendor should not be treated as a substitute for checking the actual statutory and rule obligations.
Audit package agencies should maintain
- Current independent bias audit.
- Tool/version and workflow scope.
- Public Summary of Results.
- Notice process.
- Documentation showing when sourcing ends and candidate screening begins.
Last legally reviewed: September 27, 2026.