Three US jurisdictions regulate automated employment decision tools directly, and federal anti-discrimination law applies regardless. None of this is legal advice, and details shift, so confirm with counsel before deploying anything that scores or ranks people.
New York City
Local Law 144 of 2021 requires an employer or employment agency to have a bias audit of an automated employment decision tool conducted no more than one year before its use, to publish a summary of the most recent audit results on its website, and to notify candidates that the tool will be used, how, and what data it collects [11]. The Department of Consumer and Worker Protection enforces it and can impose civil penalties between $500 and $1,500 per day [11]. Enforcement has been thin: a New York State Comptroller audit issued December 2, 2025 found the agency received two related complaints between July 2023 and June 2025, and that its review of 32 company websites flagged one issue while auditors identified at least 17 instances of potential non-compliance [11].
Illinois
Public Act 103-0804 amends the Illinois Human Rights Act effective January 1, 2026. It makes it a civil rights violation for an employer to use artificial intelligence that has the effect of subjecting employees to discrimination on the basis of protected classes, or to use zip codes as a proxy for a protected class, and it requires notice to employees when AI is used for those purposes [12].
Colorado
Colorado replaced its 2024 AI Act with Senate Bill 26-189, signed in May 2026 and taking effect January 1, 2027 [13]. Employers using automated decision technology that materially influences a consequential employment decision owe notice before deployment, notice within 30 days of an adverse decision covering the technology's role and the right to correction and meaningful human review, and three years of records. Only the state attorney general can enforce it [13].
Federal
Title VII applies to any selection procedure, automated or not, so a ranking tool is not exempt because a vendor built it, and the EEOC expects employers to validate selection procedures for the positions and purposes they are used for [10].