Pre-audit preparation — LL144 and bias audits
Your bias audit is due and you do not know what the auditor will find.
One to two weeks: find what an independent auditor would flag, and fix it before they arrive.
1-2 weeks · $8-12K · Signed off by General Counsel or Head of People
Annual
Independent bias audit required for automated employment decision tools
$500-1,500
Per day, per violation, under the NYC penalty regime
Technical readiness, not legal advice. The controls, the mechanics, and the evidence get built and verified. Whether an obligation applies to you is counsel's call — the engagement runs alongside them, and introductions to specialist counsel are part of the package.
Who this is for
- You use an automated tool anywhere in hiring or promotion and it falls under NYC Local Law 144.
- You have an audit scheduled and would rather find the problems first.
- A prior audit came back with findings and nobody has remediated them.
And who it is not
- You need the formal audit itself. That is performed by an independent auditor, by law — this engagement prepares you for it, fixes what they would find, and shortens their engagement and your bill.
- You want the result changed rather than the system fixed. That is not preparation, and it is not on offer.
What you get
- A gap analysis against what an independent auditor will actually test.
- Data and instrumentation review: whether you can even produce the required impact ratios from what you currently log.
- Remediation of what the analysis finds, at the system level.
- Notice and disclosure mechanics implemented where the obligation requires them.
- A handover pack the independent auditor can work from, which shortens their engagement and your bill.
How it runs
Week 1
Gap analysis
What the auditor will test, what your data can currently support, and where the exposure is.
Week 2
Remediation
Fix what was found, implement the notice mechanics, and assemble the pack the auditor will start from.
What it costs
$8-12K
Scales with the number of tools and decision points in scope.
Every engagement can start as a $2,500 paid pilot, credited in full against the full scope if you go ahead.
Every engagement and what it costsQuestions people actually ask
Can you run our bias audit?
No, by design. The law requires an independent auditor, and whoever built or hardened a system cannot certify it independently — a regulator would be right to object. This engagement prepares you for the auditor and fixes what they would find.
Is the enforcement real?
The New York State Comptroller published a critical review of enforcement in December 2025 calling it ineffective, and the practitioner guidance since has pointed the same direction: expect tightening, not relaxation. Preparing during a quiet period is cheaper than remediating during a loud one.
Who do we use for the formal audit?
You will get an introduction to independent auditors who do this properly. There is no referral fee in either direction, because that would compromise the independence the law is asking for.
Fifteen minutes is enough to work out whether this is the right engagement, or whether it is one of the others, or none of them.
Book a 15-min callScoping by email works too — send what you're building and the read-back comes with a recommendation on where to start — even when the right start is smaller than you expected.