Is Phenom compliant with [AI hiring](/maryland/ai-hiring-laws) laws?

Phenom is a talent experience tool that may have compliance requirements. Compliance depends on how your organization implements and uses Phenom. You're responsible for ensuring proper disclosures, candidate consent, bias audits, and data protection regardless of what Phenom provides out-of-the-box. Laws like Illinois AIVI , NYC Local Law 144 , Colorado AI Act , Texas TRAIGA , and Maryland AI Law require specific compliance steps.

What AI hiring laws apply when using Phenom?

Multiple state laws may apply when using Phenom, including: Illinois AIVI : Requires written consent before AI video analysis NYC Local Law 144 : Mandates annual bias audits for automated employment decision tools Colorado AI Act : Requires risk assessments and impact disclosures for high-risk AI systems California CCPA/CPRA : Grants candidates data rights and requires automated decision-making disclosures Texas TRAIGA : Prohibits intentional AI discrimination and requires AI interaction disclosure Maryland AI Law : Requires transparency, bias mitigation, and impact assessments for AI in employment decisions Laws apply based on where your candidates are located, not where your company is based.

Do I need a bias audit for Phenom?

If you use Phenom in New York City, you must conduct an annual independent bias audit under Local Law 144 . The audit must test for disparate impact across race/ethnicity and gender, publish results publicly, and be conducted by an independent auditor. Colorado's AI Act also requires impact assessments for high-risk AI systems starting February 2026. Maryland's AI Law mandates bias mitigation measures and reporting for regulated AI systems. Even if not legally required in your jurisdiction, regular bias testing is a best practice for any AI-powered hiring tool.

What candidate disclosures are required for Phenom?

Disclosure requirements vary by state but typically include: What AI does (e.g., resume screening, video analysis, scoring), how decisions are made , what data is collected , candidate rights (opt-out, human review, data access), and how to request alternatives . Illinois requires written consent before AI video analysis. NYC requires notice at least 10 days before use. Texas TRAIGA requires disclosure that candidates are interacting with AI. Colorado requires meaningful transparency about high-risk AI system logic. Maryland emphasizes clear notices on AI use and decision-making processes.

Can Phenom be used for hiring in all states?

Yes, but with compliance requirements that vary by state. Phenom can be used nationwide, but you must comply with all applicable state laws where your candidates are located. This may include providing AI disclosures, respecting data rights, and ensuring non-discrimination. EmployArmor automates compliance across all 50 states so you can use Phenom confidently everywhere.

Phenom AI Hiring Compliance Guide

State-by-state AI hiring compliance requirements for Phenom (Talent Experience).

Devyn Bartell

Founder & CEO, EmployArmor

Updated March 1, 2026

AI-powered talent experience platform with AI agents for HR that automates hiring, onboarding, and retention. Delivers hyper-personalized experiences across the entire talent journey.

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About Phenom

Tool Type

Talent Experience

Compliance Risk Level

Low-Medium

Key Regulatory Authorities:

• EEOC — Federal employment discrimination enforcement
• U.S. Department of Labor — Workforce regulations and guidance
• NYC Local Law 144 — Automated employment decision tools regulation

Using Phenom With vs Without EmployArmor

❌ Manual Compliance (DIY)

•Manual tracking of 50+ state laws and constant regulatory updates
•Custom disclosure templates for each state and tool combination
•Separate bias audit vendors ($15K-$50K+ annually per tool)
•Manual consent collection and compliance documentation
•Legal team review for every hiring process or tool change
•Risk of penalties: fines up to $100K+ per violation

✅ Automated Compliance with EmployArmor

•Automatic compliance across all 50 states with real-time regulatory updates
•Auto-generated, state-specific disclosures for Phenom
•Included bias audits + automated public results publishing
•Automated consent workflows with complete audit trails
•Pre-vetted compliance for every AI tool integration
•Full indemnification + compliance guarantee

Bottom line: EmployArmor wraps Phenom in a compliance layer that handles all state-specific requirements automatically, saving you $50K-$200K+ annually in legal fees, audit costs, and compliance staff time.

Phenom Compliance by State

Click on any state to see detailed compliance requirements for using Phenom with candidates in that jurisdiction.

Illinois

AIVI, BIPA

Colorado

Colorado AI Act

New York City

Local Law 144

Maryland

HB 1202

California

CCPA, CPRA, Proposed AB 331

Texas

CUBI, TRAIGA

Washington

My Health My Data Act

New Jersey

Proposed S-1943

Frequently Asked Questions: Phenom & AI Hiring Compliance

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Legal Disclaimer: This guide provides general information about AI hiring compliance and is not legal advice. Laws and regulations are subject to change and interpretation. Always consult with qualified legal counsel for advice tailored to your specific situation and compliance obligations. EmployArmor's compliance guarantee is subject to the terms of service and applicable limitations.