New Jersey A 2726 Automated Employment Decision Tool Bill: Compliance Checklist

Compliance checklist

Run through these items to scope your obligations under New Jersey A 2726 Automated Employment Decision Tool Bill. Not legal advice; verify with counsel before acting.

1. Confirm scope: does the law apply to your operations? See Who Must Comply or use the Compliance Checker.
2. Inventory in-scope AI systems and classify them by role (developer/deployer) and decision type.
3. Address each obligation:
   • bias audit — If enacted, an AEDT could not be sold, developed, deployed, used, or offered for sale in New Jersey unless the tool was subject to a bias audit in the past year and the sale included an annual bias-audit service at no additional cost.A2726 § 2(a)
   • transparency — If enacted, the AEDT developer would have to implement the recommendations from the most recent bias audit and issue a press release explaining how those recommendations were implemented.A2726 § 2(a)(4)
   • disclosure — If enacted, an employer or employment agency using an AEDT would have to notify each covered individual at least 10 business days before use through a website employment section, job posting, written policy, U.S. mail, or electronic mail, depending on whether the person is a candidate or employee.A2726 § 2(c)-(e)
   • disclosure — If enacted, an employer using an AEDT would have to provide covered individuals, within 30 days after use, notice that the tool was used, the job qualifications or characteristics assessed, data sources, retention policy, tool name, vendor, and enough adverse-outcome information to contest the employment decision.A2726 § 2(f)
   • transparency — If enacted, an employer or employment agency would have to publish the most recent bias-audit date and results on its employment website in accessible, machine-readable, downloadable form, keep the summary posted for at least 10 years after the latest AEDT use, and issue a press release when the report is made publicly available.A2726 § 2(g)
4. Adopt a federal control framework: NIST AI RMF or ISO/IEC 42001 to demonstrate due care.
5. Document evidence of compliance for each obligation, refreshed at the cadence the law requires.
6. Build the AG-notification path if the law requires it (Colorado, California SB 53).
7. Set the refresh cadence — annual for most impact-assessment regimes; continuous for monitoring.