New York Finalizes RAISE Act for Frontier AI Models; Law Takes Effect January 1, 2027: Wiley

Alert 
 April 3, 2026 
 
 New York Finalizes RAISE Act for Frontier AI Models; Law Takes Effect January 1, 2027

 April 3, 2026 On March 27, 2026, New York Governor Kathy Hochul signed into law a chapter amendment that is the final version of the Responsible AI Safety and Education Act (RAISE Act), New York’s new law regulating frontier AI models. The RAISE Act establishes a range of detailed obligations for developers of frontier models, and grants rulemaking authority to a new office within the New York Department of Financial Services (DFS). While the chapter amendment brings the final version of the RAISE Act more in line with the California Transparency in Frontier Artificial Intelligence Act ( TFAIA ), including aligning with some key definitions, other provisions of the RAISE Act are a marked departure from TFAIA, including the requirement to disclose incidents within 72 hours (TFAIA has a 15-day timeline). Accordingly, the New York law establishes another unique state standard for AI model transparency and safety, which is in tension with the Trump Administration’s efforts to promote comprehensive federal AI legislation in lieu of a fragmented patchwork of state laws. 


 Below, we provide a high-level summary of the RAISE Act, which will take effect on January 1, 2027.


 Key Background 


 The New York Governor originally signed the RAISE Act into law on December 19, 2025, following the state’s legislature passing the bill in June 2025. The Governor negotiated with lawmakers to secure a chapter amendment, which was introduced on January 6, 2026, passed the second chamber of the legislature on March 11, 2026, and was finally signed into the law by the Governor on March 27, 2026.


 Purpose and Applicability 


 The purpose of the RAISE Act is to shape AI safety protocols through transparency and safety requirements applicable to frontier developers and frontier models. Specifically, the RAISE Act applies to frontier models “developed, deployed, or operating” in New York and requires large frontier developers to establish and publish safety protocols. 


 “Frontier developer” is defined as a person who has trained a “frontier model,” defined as a foundation model trained using “computing power greater than 10°26 integer or floating-point operations.” The Act defines “foundation model” as an AI model that is:


 
 Trained on a broad data set

 Designed for generality of output

 Adaptable to a range of tasks

 
 “Large frontier developer” is defined as a frontier developer having annual revenue exceeding $500 million. Among the changes made by the chapter amendment are the addition of the computing power and revenue-based thresholds to distinguish the law’s applicability to AI models, frontier developers, and large frontier developers. These are the same thresholds as TFAIA. 


 Similar to TFAIA, the RAISE Act focuses on prevent

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