An independent assessment of AI-assisted hiring tool compliance across the four major professional services firms operating in New York City — measured against NYC Local Law 144, EEOC Uniform Guidelines, and EU AI Act Annex III requirements.
4Firms Audited
23Dimensions
17Pages
Apr 2026Published
NYC Local Law 144EEOC ComplianceEU AI Act Annex IIIQ1 2026 Data
Executive Summary
This report presents ALS Consulting's independent assessment of AI-assisted hiring tool compliance across the four major accounting and professional services firms with significant hiring operations in New York City. The audit scope covers Q4 2025 through Q1 2026 and assesses adherence to NYC Local Law 144 (effective January 1, 2023), EEOC Uniform Guidelines on Employee Selection Procedures, and EU AI Act Annex III requirements for high-risk AI systems in employment contexts.
Data was collected through public disclosures, direct regulatory filings, careers-page audits, and two rounds of structured request-for-information submissions. Where firms did not respond, findings are based on the public record as of March 31, 2026.
Key Finding: Only one of the four firms achieved full compliance across all assessed dimensions. Two firms exhibit partial compliance with critical gaps in candidate disclosure and opt-out mechanisms. One firm has not conducted a required bias audit as of the assessment date, creating significant regulatory exposure within the NYC jurisdiction.
Compliance Scorecard
All Firms — At a Glance
Compliance Dimension
Firm A
Firm B
Firm C
Firm D
Bias audit conducted (2024–2025)
✓
✓
✗
✓
Audit findings published publicly
✓
✗
✗
✓
Candidate notice posted on careers page
✓
✓
✗
✗
Opt-out mechanism offered
✓
✗
✗
✓
Selection rate disclosed by demographic
✓
✗
✗
✗
Intersectional breakdown provided
✓
✗
✗
✗
Independent third-party auditor used
✓
✗
✗
✓
Remediation plan documented
✓
⚠
✗
⚠
EU AI Act Annex III assessment completed
✓
✗
✗
✗
EEOC record retention policy on file
✓
⚠
✗
✓
Overall Assessment
Compliant
Partial
Non-Compliant
Partial
You've seen the scorecard. You've seen which firms scored HIGH RISK. What you haven't seen yet is exactly what their job postings said — word for word — and what it would cost them in a regulatory proceeding. That's in the full report.
Section 3 — Firm A Deep-Dive Analysis
Full Compliance Profile & Remediation Map
Firm A achieved the highest overall compliance score in this cohort, meeting all ten assessed dimensions. This section provides a detailed breakdown of the specific tools in scope, the bias audit methodology employed, and ALS Consulting's assessment of the robustness of each disclosure. Particular attention is given to the intersectional analysis, which represents best-in-class practice among NYC-operating firms.
Tool inventory: Firm A disclosed the use of three automated employment decision tools in active use during the assessment period. All three were included in the bias audit scope. The third-party auditor retained was [REDACTED IN PREVIEW] — a qualified entity under the NYC LL144 definition. The audit covered resume screening, video interview scoring, and structured assessment scoring across all U.S.-based roles posted in New York.
Section 4 — Firm B Deep-Dive Analysis
Partial Compliance — Critical Gaps
Firm B conducted a bias audit in Q3 2024 but did not publish the findings. A candidate notice exists internally but is not surfaced at the point of application on the careers page — a direct violation of NYC LL144 Section 3(a). The opt-out mechanism is not functional as of March 2026.
Full Report — 17 Pages
Unlock the complete findings
Section 3 onward covers every firm's full compliance profile, remediation map, regulatory exposure analysis, and ALS Consulting's rated recommendations for procurement and legal teams.
Firm-by-firm deep-dive analysis (Sections 3–6)
Regulatory exposure scoring & fine risk estimates
Remediation priority map for each firm
Procurement guidance for HR technology buyers
EU AI Act Annex III readiness comparison
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