By Matt Miller | July 6, 2026
New York’s Legislature has passed a bill that would require large employers and publicly traded companies to report every year to the state Department of Labor (“DOL”) on how they use AI and how it affects hiring. The bill hasn’t reached Governor Hochul’s desk yet, so it isn’t law — but if she signs it, it takes effect immediately. We’re issuing this alert now so you have time to prepare.
Who Would Be Covered
Employers with more than 50 employees, and all publicly traded companies.
What You’d Have to Report Each Year
- Layoffs or reduced hours caused in whole or in part by AI, new hires or increased hours caused in whole or in part by AI, and positions left unfilled because of AI adoption
- How you use AI generally — for what purposes, how often, what human oversight exists, whether it touches sensitive personal data, and what safeguards are in place
The DOL would compile these reports into a public annual report on AI’s impact on New York’s economy.
Deadlines and Penalties
The first report would be due March 1, 2027, covering all of 2026. Missing the deadline could cost up to $500 per day — but the DOL must waive or reduce the penalty if you fix the problem within 90 days of being notified.
What to Do Now
Nothing is due yet, and the DOL hasn’t issued forms or guidance. But this is a good time to start tracking your AI use — especially in recruiting, screening, onboarding, performance management, scheduling, workforce planning, and employee communications:
- What AI tools you use (e.g., Claude, ChatGPT, Lexis Protégé)
- Who uses them, and for what
- Whether they touch employee, applicant, or client data
- Whether they influence any employment decisions
- What human review happens before AI-assisted output is used
Getting organized now will make compliance much easier if and when this becomes law.
What’s Next
We’re tracking this bill closely — including whether it’s signed, whether it’s amended along the way (as happened with New York’s RAISE Act), and any DOL guidance that follows. We’ll send an update when there’s material news.
This alert is for general information only and isn’t legal advice. Contact Matt Miller with questions about how this bill may affect your business. Matt is Rupp Pfalzgraf’s Practice Area Leader for its Labor & Employment practice group and its AI Law, Compliance & Emerging Technology practice group.