URL: dfs.ny.gov Date: 2025-12-22 Class: foundational (primary-text from the NY Governor's Office + Department of Financial Services — establishes the chapter-amendments framing and the DFS Oversight Office mandate)
This is the official signing statement, issued December 22, 2025 by the New York Governor's Office and Department of Financial Services (DFS), for the chapter amendments to the RAISE Act (S6953B/A6453B), which Governor Kathy Hochul signed that day after months of negotiation. It is the primary text for the law's 72-hour incident-reporting requirement, the creation of a DFS oversight office for frontier AI, and the civil-penalty schedule of up to $1 million (first violation) and $3 million (subsequent violations) enforced by the Attorney General.
Summary of provisions
The signing statement describes the chapter amendments to the RAISE Act as imposing four principal obligations on large AI developers.
- Mandatory safety frameworks. Large AI developers must "create and publish information about their safety protocols."
- 72-hour incident reporting. Developers must "report incidents to the State within 72 hours of determining that an incident occurred."
- DFS Oversight Office. The amendments "create an oversight office within the Department of Financial Services that will assess large frontier developers and enable greater transparency. The office will issue reports annually."
- Attorney General civil enforcement. Penalties of "up to $1 million for the first violation and up to $3 million for subsequent violations" apply, enforced by the Attorney General for "failure to submit required reporting or making false statements."
The statement situates the law against California's SB 53, stating that it "builds on California's recently adopted framework," an explicit acknowledgment that New York is following the California axis.
Voices in the signing statement
The statement carries quotations from four officials.
- Governor Kathy Hochul: "By enacting the RAISE Act, New York is once again leading the nation in setting a strong and sensible standard for frontier AI safety… 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."
- DFS Acting Superintendent Kaitlin Asrow: "DFS has been a leader in developing rules that are facilitating the responsible adoption of artificial intelligence by financial services companies." Asrow frames the oversight office as continuous with the department's existing regulation of AI in financial services.
- State Senator Andrew Gournardes: "Big tech oligarchs think it's fine to put their profits ahead of our safety — we disagree." The quotation positions the bill against industry opposition.
- Assemblymember Alex Bores: "This bill moves beyond California's SB53 in significant ways… we defeated Trump's — and his donors' — attempt to stop RAISE through executive action greenlighting a Wild West for AI."
Empire AI context
The signing statement also recommits Hochul's administration to Empire AI, the state's AI consortium uniting academia, industry, and government. Empire AI was established earlier in Hochul's tenure and is framed in the statement as the innovation half of New York's combined innovation-and-safety approach.
Key claims
| Claim | Confidence | Notes |
|---|---|---|
| Hochul signed the chapter amendments to RAISE Act on Dec 22, 2025 | high | DFS press release; primary source. |
| 72-hour incident reporting requirement | high | Direct statutory text via signing statement. |
| Civil penalty schedule: up to $1M (first) / $3M (subsequent) | high | Stated in signing statement. |
| DFS Oversight Office assesses large frontier developers + publishes annual reports | high | Stated mandate. |
| RAISE Act builds on SB 53 framework | high | Hochul explicitly says so. |
| RAISE Act "moves beyond" SB 53 (Bores) | medium | Editorial assertion; the specific "moves beyond" elements aren't enumerated in the signing statement. |
Relation to California SB 53
The statement frames the RAISE Act amendments as the New York counterpart to California's SB 53, signed September 29, 2025. The two laws differ on several dimensions, as set out in the comparison below.
| Dimension | CA SB 53 (signed 2025-09-29) | NY RAISE Act amendments (signed 2025-12-22) |
|---|---|---|
| Author | Sen. Scott Wiener (D-SF) | Sen. Andrew Gournardes; Asm. Alex Bores |
| Enforcer | CA Attorney General | NY Attorney General |
| Oversight body | (none — DOT recommends updates) | DFS Oversight Office (annual reports) |
| Incident-reporting | OES; 15-day standard / 24-hr imminent | 72-hour mandatory |
| Penalty per violation | $1M | $1M first / $3M subsequent |
| Public framework requirement | Yes | Yes |
| Whistleblower protections | Yes | (not explicit in signing statement) |
| Innovation pillar | CalCompute | Empire AI |
Two elements of the New York law distinguish it from California's. First, the 72-hour mandatory incident-reporting window is shorter than California's OES standard of 15 days, with a 24-hour requirement for imminent risk. Second, the law houses oversight in DFS rather than the Office of Emergency Services, aligning frontier-AI oversight with a financial-services regulator that has pursued civil penalties against regulated firms, rather than with hazard-response institutions. Whether the 72-hour reporting requirement, the dedicated DFS oversight office, and the tiered $1M/$3M penalty schedule collectively amount to the "moves beyond" SB 53 that Bores asserts is not enumerated in the signing statement; Hochul's own framing instead emphasizes that the law "builds on California's recently adopted framework."
Federal preemption context
EO — Trump Federal Preemption of State AI Laws (Dec 11, 2025) was signed earlier in December 2025 in an attempt to greenlight federal preemption of state AI laws. Bores frames the RAISE Act enactment as a defeat of that effort. The underlying preemption legal question, which bears directly on the bill's enforceability, remains unresolved; as of May 2026 the bill is enacted and the preemption dispute is open.
Relationships
- deploys-in: New York RAISE Act (this is the signing statement primary text)
- supports: AI Pre-Release Vetting, AI Transparency, State-Level AI Regulation, California Effect
- contradicts: EO — Trump Federal Preemption of State AI Laws (Dec 11, 2025) (federal preemption push)
- depends-on: Governor Newsom signs SB 53, advancing California's world-leading artificial intelligence industry (CA Gov, September 29 2025) (explicit lineage)
- related: Kathy Hochul (created), Kaitlin Asrow (created), Andrew Gournardes (created), Alex Bores (existing), Scott Wiener, Governor Newsom signs SB 53, advancing California's world-leading artificial intelligence industry (CA Gov, September 29 2025) (sister-state companion piece)
- regulated-by: DFS Oversight Office (newly created; assesses large frontier developers; annual reports); NY Attorney General (enforcement)