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NY Legislature Advances Two Pending AI Bills on Disclosure and Hiring Reports

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23

Why it matters

New York legislators are advancing two bills that would impose distinct compliance obligations on businesses using artificial intelligence. Assembly Bill 3411B would require any user of generative AI systems to display a clear notice on the interface warning that outputs may be inaccurate. Assembly Bill 9581B targets employers and businesses using AI in hiring and workforce management, mandating annual reports to the New York Department of Labor detailing AI's impact on employment—including estimates of displaced workers, reduced hours, and unfilled positions. Businesses that fail to submit the required report by March 1 face civil penalties of up to $500 per day.

Both bills remain pending in the legislature with no current timeline for passage or implementation. The specific scope of "covered businesses" under the workforce reporting requirement has not been finalized, and the Department of Labor's enforcement mechanisms are still being defined.

These bills signal New York's intention to move from voluntary AI governance to mandatory state oversight. For businesses operating in New York, the legislation represents a material expansion of compliance risk—particularly for employers relying on AI in hiring decisions. The reporting requirement would give the state detailed visibility into labor market impacts from automation, potentially creating a template for other states. Attorneys advising companies on AI deployment should monitor both bills' progress through the legislature and begin assessing which employment practices would trigger reporting obligations if either bill passes.

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