This bill, S1169, proposes to regulate the development and use of specific artificial intelligence systems within New York [1]. Its objectives include preventing algorithmic discrimination, mandating independent audits for high-risk AI systems, and establishing enforcement mechanisms. These mechanisms include actions by the Attorney General and a private right of action [1].

Who does S1169 affect?

Considerations include organizations developing or deploying AI systems classified as "high risk" within New York State, particularly those where algorithmic discrimination could occur. This may encompass deployers utilizing AI in sensitive applications such as hiring, lending, housing, or other public-facing services. The bill's scope extends to both developers and deployers of such systems.

What is the current status of S1169?

As of the last published update, S1169 is at the "committee" stage, with bill status "In Senate Committee".

Where can I find the primary source for S1169?

The primary source for the most recent update is at https://legislation.nysenate.gov/bills/2025/S1169. AIGI publishes the full citation chain plus every approved brief on this bill.

NY, US · AI law tracker

S1169 — NY, US

S1169 is an AI governance legislation from NY, currently committee. This bill would introduce new regulations for AI systems, including required audits and anti-discrimination provisions [1]. AIGI tracks 1 primary-source update on this bill; the most recent was published on 2025-01-08.

Status & timeline

Regulatory stage: committee
Bill status: In Senate Committee
Authority / governing body: New York State Senate
Chamber: Senate
Document type: legislation

Next deadline: No fixed deadline — currently in Senate committee review

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Full obligation matrix

Actor	Obligation	Deadline	Source
provider	Develop and use AI systems in a manner that prevents algorithmic discrimination.	Upon enactment	—
deployer	Develop and use AI systems in a manner that prevents algorithmic discrimination.	Upon enactment	—
provider	Ensure independent audits are conducted for high-risk AI systems.	Upon enactment	—
deployer	Comply with requirements for independent audits of high-risk AI systems.	Upon enactment	—

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Enforcement risk score

/ 100

Announced regulation; enforcement footprint still forming.

Subscriber only

Role-based compliance checklist

compliance_officer Monitor the status of New York Senate Bill S1169 for enactment. (Ongoing)
general_counsel Evaluate potential legal obligations related to algorithmic discrimination and independent AI audits. (Upon enactment)
cto Assess existing AI systems for potential classification as 'high-risk' and evaluate current algorithmic discrimination prevention measures. (Upon enactment)
risk_manager Develop a strategy for conducting or procuring independent audits of high-risk AI systems. (Upon enactment)

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Vendor impact assessment

Vendor risk class: high
Procurement categories: hr_tech, customer_service_ai, fraud_detection, marketing_personalization, financial_decisions, healthcare_ai

Vendors providing AI solutions, particularly those involving automated decision-making in sensitive areas, will need to demonstrate robust controls for preventing algorithmic discrimination and be prepared for independent audit requirements. Clients should integrate these requirements into procurement processes.

Sample vendor questions

What processes do you have in place to prevent and detect algorithmic discrimination in your AI systems?
How do you identify if an AI system is 'high-risk' under emerging regulations, and what compliance measures are you implementing for such systems?
Can you provide documentation or evidence of independent audits conducted on your high-risk AI systems?
What data governance practices do you employ to ensure fairness and mitigate bias in AI development and deployment?
How do you ensure your AI systems allow for human oversight or intervention in critical decision-making?

Intelligence briefs (1)

legislation In Senate Committee 1/8/2025

NY S1169: Proposes AI Audits, Anti-Discrimination, & Private Right of Action

This bill would introduce new regulations for AI systems, including required audits and anti-discrimination provisions [1].

This proposal signals an expanding legislative focus on comprehensive AI governance, including enforcement and redress mechanisms at the state level.

Deadline: No fixed deadline — currently in Senate committee review

Primary source →

Frequently asked questions

What is S1169?: This bill, S1169, proposes to regulate the development and use of specific artificial intelligence systems within New York [1]. Its objectives include preventing algorithmic discrimination, mandating independent audits for high-risk AI systems, and establishing enforcement mechanisms. These mechanisms include actions by the Attorney General and a private right of action [1]. Primary source →
Why does S1169 matter?: This proposal signals an expanding legislative focus on comprehensive AI governance, including enforcement and redress mechanisms at the state level. Primary source →
Who does S1169 affect?: Considerations include organizations developing or deploying AI systems classified as "high risk" within New York State, particularly those where algorithmic discrimination could occur. This may encompass deployers utilizing AI in sensitive applications such as hiring, lending, housing, or other public-facing services. The bill's scope extends to both developers and deployers of such systems. Primary source →
What are the key dates for S1169?: No fixed deadline — currently in Senate committee review Primary source →
What is the current status of S1169?: As of the last published update, S1169 is at the "committee" stage, with bill status "In Senate Committee". Primary source →
Where can I find the primary source for S1169?: The primary source for the most recent update is at https://legislation.nysenate.gov/bills/2025/S1169. AIGI publishes the full citation chain plus every approved brief on this bill. Primary source →

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Important — about this brief

This brief is published by AIGI as a regulatory intelligence service. It contains general information about AI laws, regulations, enforcement actions, and policy signals across jurisdictions. It is not legal, compliance, audit, or risk-management advice; it does not establish an attorney-client, advisory, or fiduciary relationship; and it should not be relied upon as a substitute for professional counsel applied to specific facts and circumstances. Where the brief identifies “Issues for Review,” those are observations of questions a reader in a particular role might raise with their own legal, compliance, or risk function — not recommendations to act. AIGI expressly disclaims liability for actions taken or not taken in reliance on this brief. Subscribers in regulated industries should consult licensed professionals authorized to practice in their jurisdiction.

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Status & timeline

Intelligence briefs (1)

NY S1169: Proposes AI Audits, Anti-Discrimination, & Private Right of Action

Frequently asked questions

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