New York Enacts the RAISE Act Regulating Frontier AI Models

New York Governor Kathy Hochul signed the Responsible AI Safety and Education Act (RAISE Act) (S6953B /A6453B) on December 19, 2025, establishing New York as the second U.S. state after California to enact comprehensive legislation regulating the safety and governance of frontier AI models. The signing of the RAISE Act comes amid ongoing debate over federal and state authority to govern AI, following a recent Executive Order by President Trump aimed at limiting state AI regulation.

The RAISE Act signed into law reflects amendments negotiated between Governor Hochul and the bill’s sponsors after the Legislature passed the bill in June 2025. While the Governor’s agreed revisions to the RAISE Act are not yet part of the final enacted text at the time of this alert,[1] according to the governor’s press release, the Act mandates that large AI developers develop and publish information regarding their safety protocols and notify the State within 72 hours of identifying a qualifying safety incident. The law establishes an oversight office within the Department of Financial Services to evaluate large frontier developers and promote transparency. The law also authorizes the attorney general to bring civil actions against large frontier developers for failing to comply with reporting obligations or for making false statements. Civil penalties are up to $1 million for an initial violation and up to $3 million for subsequent violations. The Act does not authorize a private right of action.

As the governor stated, “By enacting the RAISE Act, New York is once again leading the nation in setting a strong and sensible standard for frontier AI safety, holding the biggest developers accountable for their safety and transparency protocols… This law builds on California’s recently adopted framework, creating a unified benchmark among the country’s leading tech states as the federal government lags behind, failing to implement common-sense regulations that protect the public.”

While the RAISE Act will not take effect immediately, developers of advanced AI systems should begin assessing whether their models and compute practices could bring them within the law’s scope. In particular, companies should review existing AI safety and governance documentation, evaluate their ability to identify and report qualifying incidents within the required 72-hour window, and monitor how the New York framework is implemented alongside California’s SB 53 and related federal activity.

[1] January 5, 2026.