Although New York City has made progress on the oversight of its AI systems since a 2023 audit, a new report from the Office of the New York State Comptroller (OSC) indicates that gaps remain.
“We appreciate the State Comptroller’s partnership and focus on this important topic and are reviewing the report and its recommendations,” a spokesperson for the city’s Office of Technology and Innovation (OTI) said in an email.
The initial OSC audit was released Feb. 16, 2023, assessing the city’s AI use from January 2019 to November 2022. The city released its Artificial Intelligence Action Plan in October 2023 to guide AI use and governance and by March 2024, officials were touting progress on milestones.
The Aug. 27 report, intended to assess the extent of implementation as of April 2026, underlined that OTI needs to take additional steps to make AI governance effective in the city.
“The follow-up report shows New York City has made progress on AI oversight efforts, but key oversight and accountability measures are still incomplete,” New York State Comptroller Thomas P. DiNapoli said in an email. “The city still does not maintain a complete inventory of AI tools used across agencies, lacks consistent citywide standards and has not established a formal process for public concerns related to AI systems.”
The 2023 audit offered three key recommendations for OTI. First, the city should use relevant AI governance frameworks to assess the risks of agencies’ AI use. Second, it should review past Algorithms Management and Policy Officer (AMPO) policies to identify areas OTI needs to strengthen. Third, the city should implement policies to create an effective AI governance structure. The follow-up report indicated that all three recommendations were only partially implemented.
The report requested that OTI officials provide information about any actions planned to address these gaps within 30 days of the report.
“This March, our annual Local Law 35 report featured a record number of algorithmic tools documented,” an OTI spokesperson said in an email. “Under the leadership of Chief Technology Officer Lisa Gelobter, we look forward to building on this foundation and advancing the responsible use of AI tools in city government.”
The 2023 audit established a road map for city-level AI oversight, indicating that at that time, there was not an effective AI governance framework in place. Agencies were required to report on certain types of AI use annually, but they were developing individual governance approaches, per the audit.
The audit also found that the city’s initial governance requirements for algorithmic tools were not met. The AMPO position was established by Executive Order 50 in 2019 to create a reporting framework along with policies and protocols to govern use.
AMPO did create a reporting framework, but the position was discontinued in January 2022 by Executive Order 3, which tasked OTI with guiding algorithmic tool use. The New York City Council passed a package of bills in November 2025 that called for the establishment of an independent Office of Algorithmic Data Accountability, due to be created by June. The office’s current status is unclear.
The city is not the only New York entity deemed by OSC to be lacking sufficient AI governance; in April 2025, the office reported that the state, too, had “inadequate” guidance and oversight for agencies’ AI use.
Julia Edinger is a senior staff writer for Government Technology. She has a bachelor’s degree in English from the University of Toledo and has since worked in publishing and media. She’s currently located in Ohio.