AI Compliance for HR Technology
Navigate NYC Local Law 144, Colorado AI Act, EEOC guidance, and EU AI Act for AI in hiring and employment.
AI in hiring, performance management, and employee monitoring faces the most aggressive regulatory action in 2026. NYC Local Law 144 requires annual bias audits for automated employment decision tools. Colorado SB 26-189 (effective Jan 1, 2027) requires pre-use notice and adverse-decision disclosure for ADMT used in consequential employment decisions. The EEOC has issued anti-discrimination guidance for AI hiring tools. EU AI Act Annex III classifies employment AI as high-risk. Aegis Firma helps HR tech companies and HR departments manage all of these obligations.
AI Compliance Challenges for HR Technology
Regulations That Apply to HR Technology
NYC Local Law 144 (AEDT)
NYC Local Law 144 requires annual independent bias audits for automated employment decision tools (AEDTs) used with NYC candidates or employees. Results must be published on your website.
Colorado SB 26-189 (ADMT law)
Effective January 1, 2027, Colorado requires deployers of ADMT that materially influences consequential decisions — including employment, housing, credit — to publish a pre-use notice and provide a 30-day disclosure after an adverse decision. It does not require impact assessments (that was the repealed SB 24-205).
EU AI Act — High Risk Employment
AI systems used in recruitment, CV screening, employment decisions, performance evaluation, and work allocation are classified high-risk under EU AI Act Annex III, Section 4.
EEOC / Title VII AI Guidance
Title VII, the ADA, and the ADEA apply to AI hiring tools regardless of the EEOC's own AI-specific technical-assistance guidance, which was withdrawn from eeoc.gov in January 2025. Employers remain liable for adverse impact created by third-party AI tools they deploy.
How Aegis Firma Helps HR Technology
Common Use Cases
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Frequently Asked Questions
Does NYC Local Law 144 apply to us if we use a third-party ATS with AI features?
Yes. NYC LL144 applies to any employer using an AEDT to screen candidates in New York — regardless of whether you built the tool or licensed it from a vendor. If your ATS uses AI to screen, rank, or score candidates for NYC-based roles, the bias audit obligation applies to you as the employer.
What counts as a "consequential decision" under Colorado's ADMT law?
Colorado SB 26-189 covers AI decisions in employment, credit, insurance, housing, and education. For HR, this means AI that materially influences screening candidates, employment decisions, or pay/performance classifications for Colorado-based employees, from January 1, 2027. It does not require impact assessments — the obligations are a pre-use notice and a 30-day adverse-outcome disclosure.