Developers of frontier AI models face new obligations with the introduction of California’s Transparency in Frontier Artificial Intelligence Act (TFAIA), the first law in the nation to establish transparency, disclosure and governance requirements for developers of high-compute AI models. TFAIA’s mandates warrant prompt attention. Although not many companies have exceeded the high technical threshold to be a frontier developer, that number is expected to rapidly increase, bringing far more companies into scope in the near future. Downstream businesses and users will be impacted as well. This second installment in a two-part article series, with commentary from AI law practitioners and former regulators at Crowell & Moring, Jones Walker, Mayer Brown, Skadden and Womble Bond Dickinson, provides practical compliance considerations for companies as they prepare to fulfill the new law’s obligations. Part one discussed to whom the TFAIA applies and examined the law’s reporting requirements, protections, exceptions and penalties. See “How to Address the Colorado AI Act’s ‘Complex Compliance Regime’” (Jun. 5, 2024).