We help organizations identify AI-enabled tools across the employment lifecycle, determine which may qualify as regulated AEDTs or other covered AI systems, and map the requirements that apply across relevant jurisdictions
AEDT Compliance + AI Hiring Governance
AEDT compliance covers the legal and technical obligations that apply when an employer uses AI or algorithmic tools in hiring, screening, or promotion decisions. Guidepost helps employers assess which laws apply, document their tools, and defend their AEDT program if challenged.
Our Approach
Employers are increasingly using automated employment decision tools (AEDTs) and other AI-enabled technologies to screen resumes, score candidates, assess qualifications, and support hiring and promotion decisions. But as the technology becomes more common, the regulatory landscape is becoming more complex – and the compliance risk is increasingly falling on employers that use these tools, not just the vendors that build them.
New York City’s Local Law 144 requires an independent bias audit for all covered AEDTs used in hiring, along with public disclosure and candidate notice. Colorado has enacted broader requirements governing automated decision-making technologies used in consequential decisions, including employment, while Illinois restricts discriminatory uses of AI in employment and imposes notice requirements. In the EU, AI systems used for recruitment, candidate evaluation, promotion, termination, and certain other employment decisions are generally classified as high-risk under the EU AI Act.
For employers, the challenge goes beyond identifying which laws apply. Organizations may not have a complete inventory of the AI-enabled tools already embedded in recruiting and HR processes. Vendor-provided systems may offer limited transparency into their data, methodology, or testing. And a tool that performs well overall can still produce outcomes that create discrimination concerns for particular groups. As requirements evolve across jurisdictions, employers must be able to demonstrate not only what tools they use, but how those tools were evaluated, governed, monitored, and disclosed.
We help organizations turn this evolving regulatory landscape into a defensible compliance framework. Our team works with companies across industries to identify potentially regulated tools, assess applicable requirements, build and maintain appropriate documentation, conduct and support bias audits and testing, and strengthen vendor oversight. Drawing on experience in employment law, data science, privacy, and regulatory compliance, we bridge the gap between legal requirements and the technical evidence needed to satisfy them – helping employers understand not only what the rules require, but whether their AEDT program can withstand scrutiny.
Solutions
Guidepost provides targeted support across the AEDT compliance lifecycle, from identifying covered tools and assessing legal obligations to conducting audits, strengthening governance, and preparing defensible documentation.
Regulators expect documented governance around how AEDTs are used, not just a working tool. We design practical governance frameworks[JM2.1], so they hold up to regulatory scrutiny, reflect how the business actually operates, and can be defended if challenged.
Where a bias audit is required, we conduct the independent evaluation, related testing, and prepare the report. Getting this right requires more than following a checklist. It requires judgment about data quality, statistical methodology, and how findings should be characterized in a document that may become public or undergo regulatory scrutiny.
We draft or review the required AEDT notices, translating technical and legal requirements into disclosures that are compliant, accurate, and easy to understand.
Where results must be made public, we help organizations determine what must be disclosed and how; then we draft the appropriately calibrated language that satisfies the applicable law without unnecessary disclosure.
We establish defensible recordkeeping practices for AEDT use, integrating documentation into existing compliance processes and helping organizations prepare for regulatory inquiries, audits, or investigations.
Most AEDTs are licensed, not built in house. We help organizations evaluate vendor documentation and testing to determine what additional due diligence is needed.
We provide targeted training for HR, recruiting, legal, compliance, procurement, and other stakeholders responsible for selecting, deploying, or overseeing AEDTs.
Why Guidepost
Guidepost has served as an independent monitor for regulators including the Federal Trade Commission, a role that requires the same posture an AEDT bias audit does: independent judgment, reported into a regulatory framework, and defensible if challenged.
Our compliance team includes professionals holding Certified Information Privacy Professional, Certified Information Systems Auditor, and Certified Information Systems Security Professional credentials.
Guidepost is a member of the U.S. AI Safety Institute Consortium, established under the Department of Commerce’s National Institute of Standards and Technology, and participates in the development of guidelines for responsible AI use.
Our AEDT team draws on backgrounds in employment law, data science, and privacy, so the audit accounts for how a tool is built and how it will be judged under an evolving legal framework.
Unsure whether your hiring tools trigger AEDT requirements? Guidepost can help you assess risk and build a defensible compliance framework.
Frequently Asked Questions
An automated employment decision tool is technology used to substantially assist or replace human decision making in hiring or promotion, such as resume screening software or algorithmic candidate scoring.
Requirements vary by jurisdiction and by how the tool is used. Local Law 144, for example, applies to employers using AEDTs to screen candidates for jobs in New York City. Other states and the EU AI Act impose their own thresholds. We can help determine what applies to a specific tool and use case.
Under frameworks like Local Law 144, a bias audit measures selection or scoring rates and impact ratios across gender, race, and intersectional categories, and reports how many applicants fall into an unknown category for either.
Sometimes. Whether that is appropriate depends on the vendor’s audit scope, the jurisdiction’s requirements, and the organization’s own risk tolerance. This is worth evaluating case by case.
MSU Institutional Assessment + RAMAGELLAN MonitorshipEmpire/Liberty Review