Short answer: AEDT vendors and employers usually contribute different evidence to an LL144 program. The vendor may supply system documentation, version information and audit-support data; the employer or employment agency must determine how the tool is actually used, whether the deployment is covered, and whether its own audit, publication and notice obligations are satisfied.

Direct answer

LL144's core use restriction applies to employers and employment agencies. Vendors can provide historical data, technical documentation, configuration evidence and publication support, but an independent audit must remain independent and the employer/agency must ensure the statutory conditions for use are satisfied.

AEDT vendor versus employer responsibilities under Local Law 144 A responsibility map showing vendor evidence on the left, employer deployment obligations on the right, and the independent bias audit in the center. AEDT vendor system/version evidence output meaning technical documentation data support where available change/version notices Independent audit scope + data basis required calculations professional review Employer / agency actual deployment facts NYC scope analysis public Summary candidate notices annual-use control
Vendor support and employer obligations overlap, but they are not interchangeable. Deployment-specific facts remain essential even when a vendor has commissioned an audit.

How should work be divided between the AEDT vendor and employer?

TaskEmployer / agencyVendorIndependent auditor
Describe workflowPrimarySupportVerify scope evidence
Provide product/version informationConfirm deployed configurationPrimary technical sourceReview
Provide audit dataMay provide employer historical dataMay provide pooled/vendor historical data where appropriateValidate basis
Perform bias auditMust ensure it occursCannot compromise independencePrimary
Publish resultsResponsible for availability under ruleMay host/supportProduces reliable publication output

Frequently asked questions

Payment mechanics should be reviewed for independence. The rule focuses on objective/impartial judgment and specific disqualifying relationships/interests.

The rule permits historical data from one or more employers or agencies under specified conditions; applicability to a particular employer still requires review of tool, workflow and data basis.

No. Data provenance and comparability should be documented before combining data sources.

What should be resolved before relying on a vendor audit?

Use this page for general information only. For a specific workflow, review the LL144 scope framework or request an independent bias-audit scope review.

What should HR technology vendors prepare for customers?

If you provide recruiting or assessment software to employers, see our dedicated guide to vendor-commissioned audits, historical/test data and multi-customer deployment questions.

NYC Local Law 144 bias audits for HR software vendors →