In November 2021, the New York City Council passed a bill requiring that artificial intelligence (“AI”) tools used by employers to make or assist in hiring decisions or internal promotions undergo bias audits to screen for discriminatory effects. Under the City Charter, the bill became law a month later after it was returned unsigned to the Council by then-mayor Bill DeBlasio. While the law was originally set to go into effect on January 1, 2023, the New York City Department of Consumer and Worker Protection (“DCWP”) twice delayed enforcement. Following the adoption of a final rule by DCWP (the “Final Rule”), New York City-based employers and employment agencies (defined below) must begin complying with the law on July 5, 2023, and should be aware of their obligations if they use AI to assist in making hiring or promotion decisions.