Short answer. Resume screening, ranking or matching can fall within LL144 when the system meets the AEDT definition and is used to substantially assist or replace discretion in screening candidates for a specific job. Pure sourcing or outreach before a person becomes a candidate for a specific position is treated differently in DCWP guidance.
Questions that matter
- Has the person applied for a specific position?
- Does the tool generate a score, ranking, classification or recommendation?
- Is the output the sole criterion, more heavily weighted than other criteria, or able to overrule other conclusions?
- Is the use tied to a covered NYC employment decision?
Resume bank search vs applicant screening
DCWP says AEDT use solely to scan a resume bank, conduct outreach or invite applications is not covered when the person has not applied for a specific position. Once an applicant is being assessed for a specific position, the analysis changes.
Ranking can be enough
A tool does not need to make the final hiring decision itself. LL144's employment-decision concept includes screening earlier in the process, and §5-300 focuses on whether the simplified output substantially assists or replaces discretion.
What to document
- Stage of the hiring funnel.
- Whether the person has applied to a specific position.
- Output type and meaning.
- Recruiter reliance/weighting.
- NYC nexus.
Last legally reviewed: September 27, 2026.