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New York Enacts RAISE Act for AI Transparency Amid Federal Preemption Debate (Davis Wright Tremaine, December 19, 2025)
webLegal practitioner analysis of a 2025 New York state AI safety law; useful for tracking the evolving patchwork of state-level AI governance and compliance obligations relevant to AI developers in the US.
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Importance: 42/100blog postanalysis
Summary
Davis Wright Tremaine provides legal analysis of New York's RAISE Act, a state-level AI safety law imposing transparency and safety obligations on AI developers, enacted amid ongoing debate over federal preemption of state AI regulations. The article examines key provisions affecting AI developers operating in New York and the broader regulatory landscape tensions between state and federal AI governance approaches.
Key Points
- •New York's RAISE Act establishes transparency and safety requirements specifically targeting AI developers, representing one of the more significant state-level AI safety legislative efforts.
- •The law raises federal preemption questions as states increasingly move to regulate AI in the absence of comprehensive federal AI legislation.
- •Legal analysis covers compliance obligations for AI developers, including disclosure and safety-related provisions under the Act.
- •The article reflects the accelerating trend of state-level AI governance filling the vacuum left by federal inaction on AI safety standards.
- •Developers operating in New York must navigate this new regulatory layer alongside existing federal frameworks and other state laws.
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| Page | Type | Quality |
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| New York RAISE Act | Policy | 73.0 |
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New York Enacts RAISE Act for AI Transparency Amid Federal Preemption Debate | Davis Wright Tremaine
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Artificial Intelligence
New York Enacts RAISE Act for AI Transparency Amid Federal Preemption Debate
New reporting and safety act applicable for large developers of significant models is likely to be challenged by the Trump Administration
By
Wendy Kearns ,
Apurva Dharia , and
Andrew M. Lewis
12.23.25
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UPDATE: Upon signing this bill, New York Governor Kathy Hochul indicated that she had reached an agreement with the state legislature to substantially amend the RAISE Act. The governor issued a memo accompanying her signature, which read:
I have reached an agreement with the Legislature to make certain clarifications, including adding requirements for developers to publish AI frameworks with standardized criteria to promote transparency as well as report critical safety incidents to the state within seventy-two hours of having made or reached the determination that a critical safety incident has occurred. An incident report, if any, filed by a frontier developer with respect to a frontier model that has been modified by an unaffiliated third party, may describe limitations on the frontier developer's knowledge with respect to that incident, as appropriate. Additionally, a new office to receive these reports and help facilitate transparency and safety, will be created. On the basis of this agreement, I am pleased to sign this bill.
A new bill was introduced on January 6, 2026, which, if passed, would make significant changes to the RAISE Act, largely aligning with California's Transparency In Frontier Artificial Intelligence Act (which we discussed in a prior blog post ). We will provide further updates to this post with an analysis of the New York law upon passage of the new bill.
New York Governor Kathy Hochul signed the Responsible AI Safety and Education Act ("RAISE Act"), which established the nation's first comprehensive reporting and safety governance regime for "frontier" AI model developers. The RAISE Act had originally passed in June, but the version signed on December 19, 2025 has now been modified to be more like California's AI law addressing the same issues. Although Governor Hochul is reported to have signed the original version of the bill passed in June, lawma
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