California’s new Transparency in Frontier Artificial Intelligence Act (TFAIA), signed into law last month, is the first law in the nation to impose transparency and safety obligations on certain developers of frontier AI models. The law, effective January 1, 2026, aims to highlight these models’ potential to create catastrophic risk that could result in critical safety incidents. This first article in a two-part series discusses to whom the TFAIA applies and examines the law’s reporting requirements, protections, exceptions and penalties, with commentary from AI law practitioners and former regulators at Crowell & Moring, Jones Walker, Mayer Brown, Skadden and Womble Bond Dickinson. Part two will provide practical steps covered companies can take to comply with the TFAIA. See “AI Governance: Striking the Balance Between Innovation, Ethics and Accountability” (Feb. 12, 2025).