In December 2018, Chinyere Ezie, a civil rights lawyer, posted a picture on Twitter that seemed to encapsulate a year’s worth of racial and cultural faux pas from major fashion brands.

It showed the window of the Prada shop in downtown New York filled with Pradamalia figurines that resembled monkeys in blackface. “I don’t make a lot of public posts, but right now I’m shaking with anger,” Ms. Ezie, who works at the Center for Constitutional Rights, wrote on Facebook.

Social media, especially the Twitterati and the fashion industry watchdog Diet Prada — already furious over a Gucci blackface sweater and a Dolce & Gabbana video that caricatured Chinese culture — took up the cause. Charges of racism flew.

In short order, Prada, like Gucci before it, had done away with the offending objects, apologized and vociferously declared its intention to focus on diversity.

Not everyone was satisfied.

For the last year, the New York City Commission on Human Rights, the law enforcement agency of the municipal government charged with overseeing the city’s human rights laws as they apply to housing, retail establishments and other areas, has been investigating and in settlement talks with Prada, a process culminating in a deal signed on Feb. 4, just in time to set nerves on edge during fashion month.

Prada denied any discrimination but has committed to internal re-education, engaging in financial and employment outreach with minority communities, and submitting to external monitoring of its progress for the next two years.

And Prada is not the only brand under the commission’s microscope. It has also been negotiating with Gucci post-blackface incident, and Christian Dior, for its Sauvage campaign, which perpetrated Native American stereotypes. Together these cases represent new territory for city government, which has never focused so specifically on the images and products fashion brands disseminate.

The move has rattled many in the industry, where traditionally such value judgments are left to the consumer, brands will often do almost anything to avoid tarnishing their halo or upsetting the market.

“This sounds to me like the law being stretched in a new direction that is based on a more expansive and scientifically accurate — according to social science research — interpretation of how racism operates in current society,” said Ellen Berrey, an associate professor in the sociology department at the University of Toronto, and the co-author of “Rights on Trial: How Workplace Discrimination Law Perpetuates Inequality.” “It indicates an understanding that one of the most powerful mediums for communicating racism is through cultural imagery.”

Not everyone is convinced that a municipal agency is the place to adjudicate a company’s cultural mistakes and dictate how to fix them.

James Copland, the director of legal policy for the Manhattan Institute, a conservative free-market think tank, called it “the new anti-federalism.”

“We’ve got a local decision-making body engaged in punitive regulation of international companies based abroad, which is something with wide national policy implications,” Mr. Copland said. “That is why we have a federal government.”

William Kovacic, a former commission of the Federal Trade Commission and a professor at the George Washington University Law School, suggested that the issue was also one of free speech.

“If we extend the concept of screening to other sectors, my guess is there would be an uproar,” he said. “If it’s a garment, why not a painting? But they have targeted a sector that is inclined to placate or back off instead of questioning the use of public authority in this way.”

And the result establishes precedent. Especially because the agreements are not just about punishing past offenses but shaping what may happen in the future.

Sapna V. Raj, the deputy commissioner of the law enforcement bureau of the commission, who has been overseeing the negotiations with the fashion companies, acknowledged as much. “Since she took office, one of the things the commissioner has been focusing on is anti-black racism,” Ms. Raj said, referring to Carmelyn P. Malalis, the commissioner and chair of the commission, who was appointed by Mayor Bill de Blasio in 2014. Last year Ms. Malalis expanded the commission’s interpretation of the law to ban discrimination based on hair.

“She was very interested in the kind of justice we get, so it’s not just about money for the city but about changing the culture of a brand,” Ms. Raj said.

As the Manhattan district attorney’s office once investigated the banks, so the commission is looking at the brands. It has, effectively, become the policeman of the fashion world’s race problem. Should it be?

The Prada Deal

The Commission on Human Rights has the power to open investigations into the violation of the human rights laws. (Title 8 of the Administrative Code of the City of New York, one of the most expansive human rights laws in the country, includes more than 25 categories of unlawful discrimination.)

Its powers also include the ability to subpoena witnesses and bring cases to civil trial, though in all probes involving the fashion brands the companies cooperated so quickly that the investigation phase soon segued into negotiations about how to “ensure some cultural competency and understanding of history,” according to Ms. Raj.

In December 2018, the commission, after seeing Ms. Ezie’s tweet about the Pradamalia figurines, sent Prada a “cease and desist” letter and opened discussions. On Jan. 4, Ms. Ezie filed an official complaint with the commission.

A spokeswoman for Prada responding to questions this week via email wrote that “given that the resemblance of the products to blackface was by no means intentional,” and the company had worked quickly to remedy the situation, Prada was “surprised” to hear from the commission.

“We closely collaborated with the NYCCHR and proactively addressed many of their recommendations well in advance of our agreement being finalized,” she wrote.

In February 2019, Prada announced, with great fanfare, the establishment of a Diversity and Inclusion Advisory Council, chaired by the director Ava DuVernay and the artist Theaster Gates, a move the spokeswoman wrote was “created from conversations with the Prada Group leadership and longtime collaborators well before we interacted with NYCCHR.”

Ms. Ezie said she had been having a “positive” conversation with Prada since January of 2019. In March, she met with Carlo Mazzi, the company chairman, who, she said, “confirmed something I had suspected: There were no black employees working at Prada headquarters at all” during the time of the Pradamalia incident.

Ms. Ezie’s lawyer, Uzome Eze, who was present during the March conversation, confirmed her recollection of the conversation. The Prada spokeswoman, however, denied that Mr. Mazzi had ever made this statement and wrote that “our employees worldwide represent over 100 nationalities in 40 countries.”

The commission agreement, which was seen by The New York Times, requires Prada to provide sensitivity training, including “racial equity training,” for all New York employees within 120 days of signing the agreement — as well as for executives in Milan since the commission argued that decisions made in Italy have repercussions in New York.

In other words, Miuccia Prada as well as Patrizio Bertelli, her husband and the Prada chief executive, and Mr. Mazzi will all go through training. The general counsel of Prada will report back to the commission on the executives’ compliance.

The agreement also requires Prada to appoint a diversity and inclusion officer within the next 120 days, at director level, with candidates approved by the commission. The official’s responsibilities will include “reviewing Prada’s designs before they are sold, advertised or promoted in any way in the United States.” (Given the hundreds of products Prada creates every season, this is a pretty extraordinary task.)

In addition, the agreement specifies that Prada’s Diversity and Inclusion Advisory Council already in existence will continue for at least six years. And that roughly every six months for the next two years, Prada will report to the commission on the company’s progress in achieving the agreement’s goals.

A year after signing the agreement, Prada is required to tell the commission “the demographic make-up” of its staff at every level, and summarize “Prada’s past and future activities aimed at increasing the number of people from protected classes under-represented in the fashion industry.”

Ms. Raj categorized the agreement as “highly unusual” in both its extent and proactive terms, and valued the settlement “in the millions.”

Many of the conditions within the Prada agreement mirror commitments Gucci has already announced, including the creation of scholarships and promises to diversify its design and executive team. In July, it hired Renée Tirado, its first global head of diversity and inclusion, who formerly held a similar role for Major League Baseball.

Gucci declined to comment on the status of its discussions with the commission, though it did not deny the conversations were taking place. Dior did not respond to requests for comment.

Who Polices Whom?

There is a striking discrepancy between the stories of emotional awakening the brands tell and the stories of negotiation told by the Commission on Human Rights. One side presents the new initiatives as self-motivated change, while the other describes them as legally binding strictures that apply not just in New York but globally.

The discrepancy reflects the discomfort within the fashion industry at this new development, and the fact that brands are probably afraid to litigate their positions publicly. Fashion, after all, is an industry deeply invested in the value of image.

“We share the New York City Commission on Human Rights’ commitment to ensuring that diverse perspectives are represented and respected, and we are pleased that our diversity and inclusion initiatives are aligned with their vision for a more equitable, inclusive industry,” Mr. Mazzi said in a statement. “Prada is gratified to have been able to collaborate with the New York City Commission on Human Rights on a mutually agreeable conclusion.”

While it may look better for a brand to be policing itself, an outside arbiter may actually be a better solution, according to Alexandra Kalev, a professor of sociology at Tel Aviv University who studies racial, gender and ethnic diversity in the American workplace. Most companies, Dr. Kalev said, will “do anything they can to keep the law out of their hair.”

“Their message is usually: We’ll fix it, but we’ll do it on our terms.”

As a result, she said, the monitoring framework the Commission on Human Rights has put in place are a key development. In a world in which public attention tends to be focused for a minute, then replaced by the next terrible thing, it is easy for a brand to make a remedial gesture and then move on.

“When government becomes involved, and it’s not just Facebook outrage, it’s much more likely to have real consequences,” Dr. Berrey of the University of Toronto said. “Increasingly, this kind of social-oriented change is happening at the city level.”

Still, scholarships take years to come to fruition, and hiring practices do not change overnight. Perhaps the most immediate effect of the New York City commission’s new focus will be an understanding in the fashion industry at large that an agency with broad abilities to require change is watching.

“I don’t know that we realized previously so many major fashion houses had this ignorance of the history of racism in this country,” Ms. Raj said. “We hope companies realize they need to be very careful about how they market and advertise — that they need to have a larger social and cultural consciousness.”

Ms. Ezie said she was satisfied with the Prada outcome. “I wanted this to be a moment of reckoning for the company about how they would do business for the next 20 to 30 years,” she said. “For me this represents a new model of corporate accountability. One that began with a hashtag and online advocacy and resulted in a real opportunity for off-line change.”

Robert Burke, who runs a namesake luxury consultancy, said he thought the action would have ripple effects throughout the fashion industry.

“I would think that any brand not already implementing these kinds of changes and safeguards would start to do so very quickly,” he said.