NYC Local Law 144: Whippy's Independent Bias Audit

NYC Local Law 144 is the one law on this list that actually requires an independent bias audit. If it's on your compliance checklist, here's the short version: Whippy's AI recruiter is already audited against it, on an ongoing basis, by an independent third party. Below, exactly how that testing works and where to check the current results yourself.

The Law Behind the Question

NYC Local Law 144 is the most prescriptive AI hiring regulation in the country, and the only US law that legally mandates an independent bias audit for automated employment decision tools (AEDTs), rather than treating it as a best practice. Enforced by the NYC Department of Consumer and Worker Protection (DCWP), it requires employers to have their AEDT independently audited before deployment and annually thereafter, notify candidates that an AEDT is in use, and publish a summary of the audit results.

Enforcement gaps have also come under scrutiny. A December 2025 New York State Comptroller audit found DCWP's own compliance review missed the majority of potential violations among the companies it checked, identifying only 1 issue where the Comptroller's office found 17. Having documented, ongoing bias-audit evidence in hand puts you ahead of that gap, regardless of how enforcement evolves.

How Whippy Is Audited Against It

Whippy commissions ongoing independent bias audits of its AI recruiter through Warden AI, using two complementary methods: disparate impact analysis, which compares outcomes across demographic groups, and counterfactual analysis, which tests whether changing a single protected characteristic alone changes the outcome. For the full breakdown of how each method works, see Whippy AI Recruiter: Independent Bias Audit Results.

The audit is structured to meet the specific bias-testing requirements DCWP has published for AEDTs under Local Law 144. Warden runs disparate impact analysis across three categories:

1. 

   Sex bias: outcomes compared between male and female candidates

2. 

   Race/ethnicity bias: outcomes compared across race and ethnicity

3. 

   Intersectional bias: outcomes compared across combinations of sex and race/ethnicity together, since a system can look fair on each dimension individually while still producing disparities at the intersection

Because Whippy doesn't have access to the kind of historical candidate data these audits are typically built on, Warden runs the analysis against its own independent dataset of real candidate profiles instead. That's a deliberate design choice. It keeps the audit's inputs outside our control, same as its outputs.

What This Gives You, Precisely

An audit like this is strongest when it's specific about its own scope, so here's exactly what it does and doesn't cover.

This audit demonstrates the bias-testing component of Local Law 144: independent, ongoing, third-party evidence that Whippy's AI recruiter has been evaluated for disparate impact across the categories the law is concerned with. It's the piece of Local Law 144 compliance that a vendor can actually own and hand you documentation for.

Two things sit outside that scope, and are worth being upfront about because they don't sit with us. Local Law 144 also requires candidate notice and public disclosure of results, obligations that belong to the employer deploying the tool, not the vendor providing it. And an audit report, however rigorous, reflects system behavior under tested conditions at a point in time; it isn't a legal certification and doesn't guarantee outcomes for your specific deployment. That's precisely why the testing is ongoing rather than one-and-done, and why we'd rather hand you the actual report than a summary claim.

See the Current Results

Warden re-runs this audit on a recurring basis, so what you'll find isn't a static result from months ago, it's current. Review the full NYC-specific report, methodology, and latest findings across all three categories on Warden's public dashboard, hosted independently of Whippy.

Warden's AI Assurance Dashboard →

Beyond New York

Local Law 144 is the only law that currently mandates this kind of audit. We test against it anyway in four other jurisdictions, because if your hiring spans state lines, one jurisdiction's audit only tells part of the story.

• Whippy AI Recruiter: Independent Bias Audit Results →

• California FEHA →

• Colorado SB 26-189 →

• Illinois HB 3773 →

• EU AI Act →

Whippy is an AI-powered communication and recruiting platform built to help teams move faster without sacrificing quality or fairness.