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One of these has been enforced for three years. The other just moved its own deadline. Neither is optional to understand.
You searched “AI hiring compliance requirements” and got three law firm blog posts, a vendor's marketing page calling itself “fully compliant,” and a regulation that may or may not have changed since any of them were written.
This happens because AI hiring regulation is a moving target right now — but two specific rules are worth knowing, because they're the ones most likely to actually apply to you.
What NYC Local Law 144 Actually Requires
If you use an automated employment decision tool (AEDT) to screen or rank candidates for a role based in New York City, Local Law 144 has applied to you since July 2023.
It requires four specific things: an independent bias audit conducted within the past year, a summary of that audit published publicly, notice to candidates that an AEDT is being used at least ten business days in advance, and a way for candidates to request an alternative process or accommodation.
None of this is a suggestion. Penalties accrue per violation, per day. If your hiring touches NYC in any way — even a fully remote role headquartered elsewhere with NYC-based candidates — this is worth confirming directly with whoever owns compliance, not assuming your vendor has it handled.
What the EU AI Act Actually Requires (And When)
The EU AI Act classifies AI systems used in recruitment and employment decisions as “high-risk,” which triggers a specific set of obligations: a documented risk management system, data governance standards, technical documentation, human oversight built into the workflow, and transparency to the people affected by it.
Here's the part that changed recently: high-risk obligations were originally set to become enforceable on August 2, 2026.
In May 2026, EU institutions reached a political agreement — part of what's being called the “Digital Omnibus” — pushing that date to December 2, 2027.
Formal adoption is still pending as of this writing, but every legal tracker covering it treats the delay as effectively settled. Worth knowing so you're not caught citing a deadline that's already moved.
A later enforcement date doesn't mean the underlying requirements went away. It means you have more runway to meet them properly instead of scrambling.
What This Means If You're Not in NYC or the EU
The instinct is to treat these as two narrow, geography-specific rules that don't apply to you.
Resist that instinct.
Both regulations describe what baseline, defensible AI hiring practices look like — independent audits, disclosure, human oversight — regardless of whether your specific jurisdiction currently requires it.
The compliance floor is rising everywhere, and organizations that build to it now, before it's mandatory where they operate, spend far less retrofitting later than organizations that wait to be told.
How to Check Where You Actually Stand
You don't need a legal team to get a first read on this. Ask your current vendor directly: who conducted your most recent bias audit, and is it independent of you?
Is the summary published somewhere a candidate or regulator could actually find it? Do candidates get notified before the tool is used, with a real way to opt out? If any answer is vague, that's the answer.
Part of the Transparent AI in Hiring Series. For the full vendor evaluation framework, download the Transparent AI Vendor Evaluation Scorecard at getclara.io.
Sources
New York City Department of Consumer and Worker Protection. Automated Employment Decision Tools (Local Law 144).
European Commission. Regulatory Framework for AI — EU AI Act.
About CLARA
CLARA is a skills-based hiring platform built for mid-market companies. We measure critical thinking, learning agility, and Distance Traveled—the validated competencies that predict performance, not pedigree. Filter great talent in, not out. Learn more at getclara.io.