HireCompliant · Guides
The Multi-State AI Hiring Compliance Map (2026–2027)
There is no federal AI hiring law. There are eight state and local ones, inconsistent by design — and where your applicants sit, not where you sit, decides which apply. Here is the whole patchwork in one place.
Published 2026-07-03 · verified against enrolled statute text
Green: jurisdictions with an AI employment law on the books. NY = New York City Local Law 144.
Why one ruleset can't work
Illinois binds at one employee and reaches unintentional discrimination. Colorado regulates "consequential decisions" and demands a 30-day adverse-outcome letter. Connecticut phases duties in through October 2027. New York City requires a published bias audit before the tool touches a candidate. California extends record retention to four years and can treat your vendor as the employer. These frameworks do not share definitions, timing, or enforcers — the only workable approach is per-state obligations plus a strictest-common-denominator baseline.
State by state
Illinois
HB 3773 / P.A. 103-0804, codified at 775 ILCS 5/2-102(L) (Illinois Human Rights Act) · In effect, rules pending · effective 2026-01-01
2-102(L)(1): civil rights violation to use AI 'that has the effect of subjecting employees to discrimination on the basis of protected classes' (effect-based — no intent required) or to use zip codes as a proxy for protected classes. 2-102(L)(2): failure to provide notice of AI use for those purposes is itself a violation. Draft IDHR rules define 'use' as any instance in which AI output 'influences or facilitates a covered employment decision' (draft 56 Ill. Adm. Code 2520.900).
Affirmative obligations: Pre use notice · Vendor liability · Documentation retention
Colorado
SB 26-189 · Not yet effective · effective 2027-01-01
'Materially influence' = ADMT output is a non-de-minimis factor AND affects the outcome (constraining, ranking, scoring, recommending, classifying, or otherwise meaningfully altering how the decision is made); excludes incidental, trivial or clerical uses (6-1-1701(13)). 'Consequential decision' excludes low-stakes/routine processes (routine scheduling, administrative routing, workflow management), advertising/marketing, non-ML spreadsheets, summarize-for-human-review without a score/ranking/inference, narrow procedural tasks, cybersecurity/fraud/AML/sanctions (6-1-1701(3)(b)).
Affirmative obligations: Pre use notice · Post decision disclosure · Human review or appeal · Vendor liability · Documentation retention
Texas
TRAIGA / HB 149 (Tex. Bus. & Com. Code 552.001 et seq.) · In effect · effective 2026-01-01
Private-sector liability is INTENT-based: prohibits AI systems that intentionally discriminate against a protected class. Disparate impact alone is not sufficient.
Affirmative obligations: none — prohibitions/liability model.
California
FEHA Automated-Decision Systems regulations (Civil Rights Council), 2 CCR · In effect · effective 2025-10-01
Use of an ADS in any employment decision under existing FEHA discrimination law. VERIFIED 'agent' definition (Sec. 11008(b)): 'any person acting on behalf of an employer, directly or indirectly, to exercise a function traditionally exercised by the employer or any other FEHA-regulated activity... including when such activities and decisions are conducted in whole or in part through the use of an automated decision system' — and an agent of an employer is itself an 'employer' under FEHA, so ADS VENDORS can be directly covered.
Affirmative obligations: Ai inventory · Vendor liability · Documentation retention
Connecticut
Public Act No. 26-15 (Substitute SB 5, 2026) · Phasing in · effective 2026-10-01
Output is a 'substantial factor' — meaningfully alters the outcome of an employment-related decision (Sec. 7(8)). 'Employment-related decision' = hire, promote, discipline, discharge, renew, select for training/apprenticeship, or tenure/terms/privileges/conditions of employment; EXCLUDES nonmaterial changes to tasks/hours/assignments and decisions about workplace health & safety, scheduling and planning, or productivity monitoring (Sec. 7(5)). Using the tool is NOT a defense to CFEPA discrimination claims (Secs. 13-14).
Affirmative obligations: Pre use notice · Vendor liability
New York (NYC local)
NYC Local Law 144 (AEDT) · In effect · effective 2023-07-05
AEDT substantially assists or replaces discretionary decision-making for hiring/promotion.
Affirmative obligations: Pre use notice · Bias audit · Vendor liability · Documentation retention
Maryland
HB 1202 (2020), Ch. 446 · In effect · effective 2020-10-01
3-717(b): employer may not use a facial recognition service FOR THE PURPOSE OF CREATING A FACIAL TEMPLATE during an applicant's interview unless the applicant consents by signed waiver (3-717(c)).
Affirmative obligations: Consent
Utah
SB 149 · In effect · effective 2024-05-01
GenAI interacting with a person: disclose on request; regulated professions must disclose proactively.
Affirmative obligations: Pre use notice
The deadline calendar
- 2026-10-01 — Connecticut PA 26-15: AI tool use is no longer a defense to CFEPA discrimination claims (anti-bias testing evidence weighable); AI-related layoff disclosure added to federal WARN filings (Secs. 13, 14, 26)
- 2027-01-01 — Colorado SB 26-189 (C.R.S. Part 17) effective — applies to consequential decisions made on/after this date; AG clarifying rules on adverse-outcome disclosures due by same date
- 2027-01-01 — California CCPA ADMT pre-use notices + opt-outs effective
- 2027-10-01 — Connecticut PA 26-15: pre-decision written notice (6 elements), interaction disclosure, and developer information duties attach to automated employment-related decision technologies deployed on or after this date (Secs. 8-11)
The remote-hiring trap
None of these laws care where the employer sits. NYC Local Law 144 covers candidates for jobs performed in or associated with the city. Illinois binds any employer with one Illinois employee. Colorado's definition of consumer includes any Colorado-resident applicant. A Texas company screening one remote applicant in Chicago is an Illinois employer for these purposes.
Every claim on this page carries its citation in the checker — each state's record links the enrolled statute text it was verified against, with the verification date.
See every state's obligations in one place
Pick where you hire and which AI tools you use — the checker shows exactly what attaches, and when.
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