Every state with an AI hiring law is a liability. If you use AI in recruiting, promotion, or termination — you're regulated.
The pain
AI hiring tools face the most aggressive state-level regulation of any AI use case. Bias audits, candidate disclosures, and private rights of action make this the highest-risk category.
NYC Local Law 144Illinois HB 3773Colorado SB 26-189Maryland HB 1202Title VII
Laws that likely apply to you
NYC Local Law 144 — the only US law mandating a named bias audit: independent audit within the prior year, published summary, 10 business days' candidate notice. Penalties run $500–$1,500 per violation, and each day of use without notice is a separate violation
Illinois HB 3773 — in effect since Jan 1, 2026: discriminatory AI in employment decisions is a civil-rights violation, zip code as a proxy for race is barred, and notice is required. IDHR's notice rules were withdrawn, so the statutory duty stands while the detail is unsettled
Colorado SB 26-189 — from Jan 1, 2027: notice at the point of interaction and a right to meaningful human review after an adverse consequential decision, including hiring
Illinois AI Video Interview Act — notice, consent and deletion on request for AI analysis of video interviews
Maryland HB 1202 — no facial recognition during an applicant interview without a signed waiver
Title VII / ADA / ADEA — employers own the outcomes of vendor tools. Private disparate-impact litigation continues regardless of federal enforcement posture
Note on the states you may have heard about: Virginia's high-risk AI bill (HB 2094) was vetoed in March 2025, and Colorado's original AI Act (SB 24-205) was repealed before it ever took effect. Neither imposes obligations today. We would rather tell you a law does not apply than pad the list.
What we do
We help HR tech companies and employers map their hiring-AI obligations, conduct bias audits, and build governance programs that satisfy regulators.