A Cooley analysis reports that New York's governor signed the original RAISE Act in December 2025 and an amended version on 27 March 2026, taking effect on 1 January 2027. This applies to developers of very large frontier models, not to ordinary business users, but it shapes the vendors you rely on.
Key points as reported
- A 'large frontier developer' is one with annual gross revenue above $500 million.
- A frontier model is one trained with more than 10^26 operations.
- Penalties were reduced to $1 million for a first violation and $3 million for later ones.
- Critical safety incidents must be reported within 72 hours, or 24 hours where there is imminent risk of death or serious injury.
- Oversight sits with a new office in the state's Department of Financial Services.
- The annual third-party audit requirement was dropped.
Why buyers should care
Model vendors are facing a growing patchwork of safety and incident-reporting rules. In due diligence, ask which of these regimes apply to the provider, and how incident notices would reach you.
This is general information, not legal advice. Check the statute and speak to counsel before relying on any detail.