New York RAISE Act for Frontier AI Models

New York first enacted the RAISE Act in 2025. Governor Hochul signed Chapter Amendment S8828 on March 27, 2026; it replaced Article 44-B and set its effective date to January 1, 2027. The amended text controls. It defines a frontier model as a foundation model trained using more than 10^26 integer or floating-point operations, counting original training and subsequent fine-tuning, reinforcement learning, or other material modifications. A frontier developer trains or initiates training at that threshold. A large frontier developer and its affiliates exceeded $500 million in annual gross revenue in the preceding calendar year. Large frontier developers must publish and follow a frontier AI framework covering catastrophic-risk thresholds and assessment, mitigations, third-party assessment, deployment review, cybersecurity for unreleased model weights, incident response, internal governance, and risks from internal use. They review the framework at least annually and publish a justification within 30 days after a material modification. Before deployment of a new or substantially modified frontier model, frontier developers publish a transparency report; large frontier developers include summaries of assessments and mitigation steps. All frontier developers have incident-reporting duties under the amended text. A critical safety incident must be reported to the state office within 72 hours after a determination or after learning facts sufficient for a reasonable belief that one occurred. If the developer discovers that the incident poses an imminent risk of death or serious physical injury, disclosure to an appropriate authority is required within 24 hours. Specified violations carry penalties up to $1 million initially and $3 million for repeats; no private right of action is created. The 2026 amendment changed the Act’s scope and effective date. A compliance inventory should separate frontier developers from large frontier developers, identify affiliates and compute, and track the office’s implementing rules. The statute applies to frontier models developed, deployed, or operating in whole or part in New York, subject to exceptions and any designated federal-equivalence pathway.