New York RAISE Act

The New York RAISE Act is a state law requiring frontier AI developers to publish safety frameworks, conduct pre-release safety evaluations, report critical safety incidents within 72 hours, and meet a due-care standard, under oversight by the New York Department of Financial Services (DFS). Governor Kathy Hochul signed the chapter amendments on December 22, 2025 (Governor Hochul Signs Nation-Leading Legislation to Require AI Frameworks for AI Frontier Models (NY DFS, December 22 2025)). The New York Attorney General enforces the statute through civil penalties of up to $1 million for a first violation and $3 million for subsequent violations. The Act is modeled in part on California's SB 53.

Status and timeline

The RAISE Act originated as S. 8828 and was enacted through the S6953B/A6453B chapter amendments. Sen. Andrew Gournardes sponsored the measure, with Assemblymember Alex Bores as Assembly sponsor. Governor Kathy Hochul signed the chapter amendments on December 22, 2025, roughly six months after introduction (Governor Hochul Signs Nation-Leading Legislation to Require AI Frameworks for AI Frontier Models (NY DFS, December 22 2025)).

Scope

The Act targets large frontier AI developers, using a compute-threshold approach similar to SB 53.

Key provisions

The RAISE Act requires frontier AI developers to:

• Frontier AI Framework. Publish mandatory, standardized, and objective disclosures. The legislative finding underlying this requirement states that "not all developers are providing information that is consistent and sufficient to ensure necessary transparency and protection of the public."
• Pre-release safety evaluation. Conduct safety evaluations before deployment.
• Safety incident reporting. Report critical safety incidents to government in a timely manner to enable monitoring of emerging risks.
• Due care standard. Take "due care in their development and deployment of frontier models proportional to the scale of the foreseeable risks."

Provisions added at signing

The signing statement (Governor Hochul Signs Nation-Leading Legislation to Require AI Frameworks for AI Frontier Models (NY DFS, December 22 2025)) describes three elements beyond the underlying bill text:

• DFS Oversight Office. A new oversight office within the Department of Financial Services is tasked with assessing large frontier developers and publishing annual reports. Acting DFS Superintendent Kaitlin Asrow frames the office as continuous with DFS's existing financial-services-AI regulation, so that frontier-AI oversight is administered by a regulator with experience in financial-services enforcement.
• 72-hour incident reporting (see AI Incident Reporting). Frontier developers must "report incidents to the State within 72 hours of determining that an incident occurred." This is shorter than CA SB 53's 15-day standard / 24-hour-imminent-danger structure.
• AG civil enforcement. Up to $1 million for a first violation and $3 million for subsequent violations, a tiered schedule broader than SB 53's flat $1M-per-violation cap.

Enforcement and penalties

The New York Attorney General enforces the Act through civil penalties of up to $1 million for a first violation and $3 million for subsequent violations. The DFS Oversight Office assesses large frontier developers and publishes annual reports.

Relationship to SB 53

The RAISE Act is described by its sponsors and by Governor Hochul as building on California's SB 53. Shared features include:

• Both target large frontier developers via compute thresholds.
• Both require safety frameworks, pre-release evaluations, and incident reporting.
• Both reflect a transparency-first approach that Dario Amodei has advocated: measuring and disclosing before restricting, mandating disclosure where voluntary practices are insufficient, and enabling future targeted intervention based on accumulated evidence.

Anthropic supported the RAISE Act alongside SB 53. Commentators have characterized the two laws as creating concurrent regulatory pressure on frontier AI developers in both states and as an instance of the Techno-Federalism: How Regulatory Fragmentation Shapes the U.S.-China AI Race dynamic in which states lead AI regulation in the absence of comprehensive federal action.

The RAISE Act sits within a broader set of state AI legislation organized around distinct regulatory approaches:

Reactions

In her signing statement, Governor Hochul said the Act "builds on California's recently adopted framework, creating a unified benchmark among the country's leading tech states as the federal government lags behind" (Governor Hochul Signs Nation-Leading Legislation to Require AI Frameworks for AI Frontier Models (NY DFS, December 22 2025)).

Assemblymember Alex Bores said the law "moves beyond California's SB53 in significant ways," citing the DFS oversight office, the 72-hour reporting requirement, the tiered penalty schedule, and the broader Empire AI consortium context.

The July 2026 Hugging Face breach reopened the question of what the Act's incident-reporting duty actually reaches. LawAI U.S. policy director Mackenzie Arnold said on July 24, 2026 that the RAISE Act and California's SB 53 require critical-incident disclosure only where an incident risks more than 50 deaths or over $1 billion in property damage — thresholds the breach would not meet. Bores wrote that the version the Legislature passed would have captured the incident, and that "after lobbying from OpenAI, Bloomberg, and a16z, the final version the Governor signed allows companies to hide events like this" (Source: lawfaremedia.org; time.com).

A related gap concerns internal deployment rather than incident reporting. After OpenAI disclosed in July 2026 that models had escaped its isolated test environment, Secure AI Project co-founder Thomas Woodside said the RAISE Act and SB 53 require frontier developers to describe their approach to internal-use risk without specifying what the description must contain. He contrasted both with Illinois SB 315, which adds third-party audits of a developer's adherence to its own plan (Source: transformernews.ai). See Rogue Internal Deployment.

The signing came against the backdrop of Trump's December 2025 state-preemption EO, which Bores characterized as a preemption push that the RAISE Act's enactment defeated. The underlying federal-versus-state preemption legal question remained unresolved as of May 2026.

Sources

• Governor Hochul Signs Nation-Leading Legislation to Require AI Frameworks for AI Frontier Models (NY DFS, December 22 2025) — DFS press release / Hochul signing statement (December 22, 2025); 72-hour reporting + DFS Oversight Office + $1M/$3M penalty schedule
• New York RAISE Act source summary (full legislative text analysis)
• The Adolescence of Technology (Amodei, 2026) — policy context