From Transparency to Oversight: New York’s RAISE Act Raises the Bar for Frontier AI Developers

On December 19, 2025, Governor Kathy Hochul signed the Responsible AI Safety and Education Act (RAISE Act) into law, focusing on frontier AI models and targeting safety, transparency, and reporting incidents of catastrophic harm.
The RAISE Act applies to large developers of frontier AI models that operate in New York, requiring detailed safety, security protocols, documentation, annual independent audits, and reporting safety incidents within 72 hours.
Compared to California’s SB 53, the RAISE Act is more prescriptive with mandatory compliance measures including annual third-party audits and a stricter safety-incident reporting timeline.
While the federal government issued an Executive Order targeting AI regulation, it does not preempt state laws, increasing the likelihood of legal scrutiny and federal-state conflicts but it allows for continued operation of state regulations in the short term.
The RAISE Act represents a more demanding regulatory environment for highly capable AI models but applies to the largest developers only, creating additional obligations for companies that meet its specific thresholds.

From Transparency to Oversight: New York’s RAISE Act Raises the Bar for Frontier AI Developers | Kilpatrick