In New York, AI is shaped less by one broad statute than by three specific pieces: New York City's Local Law 144, which has required bias audits of automated hiring tools since enforcement began on July 5, 2023; a state law on frontier AI models, the RAISE Act, which takes effect on January 1, 2027; and Empire AI, a publicly funded computing consortium whose Beta system went online at the University at Buffalo in August 2026. Each covers a different group: employers, the largest model developers, and university researchers.
Key takeaways
- Local Law 144 bars New York City employers from using an automated employment decision tool unless it had a bias audit within the past year and a summary is public.
- Candidates who live in the city must get notice at least ten business days before such a tool is used.
- A State Comptroller audit issued in December 2025 found city enforcement of the hiring law ineffective, and the city agreed to adopt most recommendations in part or in full.
- The RAISE Act was signed on December 19, 2025, amended in March 2026, and starts on January 1, 2027.
- Empire AI Beta cost USD 40 million and had more than 300 research projects waiting to use it when it opened.
The hiring law: what employers in New York City must do
Local Law 144 of 2021 covers any "automated employment decision tool," defined as a computational process derived from machine learning, statistical modeling, data analytics, or artificial intelligence that issues a simplified output (a score, classification, or recommendation) used to substantially assist or replace discretionary decision making in screening candidates or employees for promotion in the city. The text carves out tools such as a junk email filter, firewall, antivirus software, calculator, spreadsheet, or database that do not materially affect people. The city's Department of Consumer and Worker Protection (DCWP) states that it began enforcement of the law and its rule on July 5, 2023.
The duties fall into three groups, set out in the table below. The summary is general information from the law's text, not legal advice, and employers with specific questions should consult counsel.
| Duty | What the law text says |
|---|---|
| Bias audit | An impartial evaluation by an independent auditor, conducted no more than one year before the tool is used, testing disparate impact |
| Public summary | Results of the most recent audit and the distribution date of the tool posted on the employer's or agency's website before use |
| Notice to candidates | Notice to each city resident at least ten business days before use, including how to request an alternative selection process or accommodation, and the job qualifications and characteristics the tool will assess |
| Data information | Type of data collected, its source, and the retention policy, provided within 30 days of a written request if not already on the website |
| Penalties | Up to USD 500 for a first violation, and USD 500 to USD 1,500 for each later one; each day of unlawful use is a separate violation |
How enforcement has gone
A December 2, 2025 audit by the New York State Comptroller examined DCWP's enforcement from July 2023 through June 2025. According to the Comptroller's published summary and law-firm reports of it, the audit concluded that enforcement was ineffective, pointing to problems with how complaints were handled and with the accuracy of compliance reviews. DCWP's position was that employers decide for themselves whether to post audits and notify applicants, which makes noncompliance hard to detect. It disagreed with some findings but agreed to adopt most of the recommendations in part or in full, including better routing of complaints, staff training, written procedures, and interviews and demonstrations of the tools where appropriate.
For job seekers, the practical point is that the notice and the posted audit summary are the main visible traces of the law. An applicant in the city who is screened by software and sees neither has a basis for asking the employer about it.
The RAISE Act: rules for the largest model developers
New York's Responsible AI Safety and Education (RAISE) Act is aimed at developers of "frontier" models, not at ordinary businesses that buy AI products. Governor Kathy Hochul signed the bill on December 19, 2025, according to the state Senate's action log. A chapter amendment that reworked the law was signed on March 27, 2026, and law-firm reports say that the final version takes effect on January 1, 2027, with incident reporting to a state office within 72 hours and enforcement by the Attorney General.
Because the amendment changed thresholds and penalty levels from the first version, anyone relying on specific figures should read the enacted text. The details above are limited to those that the sources agree on.
Empire AI: public computing for universities
Empire AI is a consortium that gives New York researchers access to shared AI computing. On August 5, 2026, the Governor's office announced that Empire AI Beta was fully online at the State University of New York at Buffalo. The announcement lists these figures, which are the state's own claims and not independent benchmarks:
- A cost of USD 40 million for the NVIDIA-powered system.
- An 11-fold increase in AI training capacity, a 40-fold increase in inference capacity, and an 8-fold increase in data storage compared with the first system, Empire AI Alpha, which launched in 2024.
- More than 300 projects queued to use Beta, after Alpha supported more than 130 projects.
- Ten member institutions, among them SUNY, CUNY, Columbia, Cornell, New York University, and the Flatiron Institute.
- More than USD 500 million in total public and private funding for Empire AI.
The release also says a permanent facility called Gamma is expected at Buffalo by the end of 2027, and that the National Science Foundation's new AI infrastructure hubs followed the same principle as Empire AI. University at Buffalo reporting lists health care, climate science, advanced manufacturing, education, cybersecurity, and public safety among the research areas.
Which piece matters to whom
- A job seeker in New York City: Local Law 144 notices and the posted audit summary.
- An employer or recruiter with city candidates: the audit, posting, and notice duties, and the daily penalty rule.
- A company training very large models: the RAISE Act from January 1, 2027.
- A university researcher at a member institution: Empire AI computing time.
FAQ
Does Local Law 144 apply outside New York City?
No. It applies to employers and employment agencies using these tools to screen candidates or employees for employment decisions in the city. Other places have their own rules or none.
Does a resume-screening tool always count as an automated employment decision tool?
Only if it fits the definition: it must issue a simplified output that substantially assists or replaces discretionary decision making. Tools that do not materially affect people, such as a spreadsheet or calculator, are excluded by name.
Is the RAISE Act already in force?
Not as of October 23, 2026. The final version is reported to take effect on January 1, 2027.
Can the public use Empire AI computers?
The system is for researchers at New York's public and private universities, not for general public access.
Related reading
- AI in data science work
- Artificial intelligence in education
- Companies building artificial intelligence
- AI and automation in industry
More in AI Basics.
Last verified: October 2026
Sources
- Local Law 144 of 2021, Automated Employment Decision Tools, Council of the City of New York, 2021
- Automated Employment Decision Tools, NYC Department of Consumer and Worker Protection, 2023
- Enforcement of Local Law 144 audit, Office of the New York State Comptroller, December 2, 2025
- Senate Bill S6953, Responsible AI Safety and Education Act, New York State Senate, 2025
- New York Finalizes RAISE Act for Frontier AI Models, Wiley, 2026
- Governor Hochul announces Empire AI Beta fully online, Office of the Governor of New York, August 5, 2026
- Empire AI Beta, University at Buffalo, UBNow, August 10, 2026