The employer must verify audit: What assumption must change? | AIGP
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The employer must verify audit: What assumption must change?

AIGP Understanding How Laws, Standards and Frameworks Apply to AI Medium

Covered New York City use requires checking the employer’s audit, public-summary, and notice obligations, even with vendor assistance.

The question

An employer begins using a covered automated employment decision tool in New York City. The vendor supplies a bias-audit report, but the employer has not checked whether its own use satisfies the city’s audit, public-summary, and notice requirements. What assumption must change?

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  1. The employer must verify audit, summary, and notice compliance. ✓
    For a stated covered tool, the employer must address the city’s required audit, public summary, and notices rather than rely passively on the vendor.
  2. Coverage depends only on whether the tool is accurate.
    New York City coverage and duties are not reduced to accuracy; covered use triggers specified governance requirements.
  3. The vendor report automatically fulfills every employer duty.
    A vendor report may provide evidence, but the covered employer must still satisfy applicable audit, summary, and notice requirements.
  4. A federal approval replaces the city’s municipal requirements.
    The evidence identifies a New York City rule, not a federal approval scheme that displaces its requirements.
The trap
Identify the regulated actor and confirm each required municipal deliverable separately.

How to remember it

Covered New York City use requires checking the employer’s audit, public-summary, and notice obligations, even with vendor assistance.

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