New York has joined California as a leading regulator of frontier AI developers and models. In December, Governor Hochul signed the Responsible Artificial Intelligence Safety and Education (RAISE) Act into law and announced an agreement with the New York State Legislature to amend that law to further harmonize it with California’s Transparency in Frontier Artificial Intelligence Act (TFAIA). This article discusses the principal features of the proposed amended RAISE Act and some distinctions from the TFAIA. It also offers compliance measures for covered companies to consider, with insights from experts at Davis Wright Tremaine, DLA Piper, Eversheds Sutherland, Gibson Dunn and Morrison Foerster. See our two-part series on California’s landmark AI transparency law: “Covered Entities, Reporting Requirements and Penalties” (Oct. 29, 2025), and “Compliance Considerations” (Nov. 5, 2025).
