Summary
- The Governor signed the original bill on 19 Dec 2025 on condition of a rewrite. That chapter amendment (S8828), signed 27 Mar 2026, replaced Article 44-B with new sections 1420 to 1429 that closely follow California SB 53 (TFAIA).
- Same thresholds as California: frontier model trained with more than 10^26 operations (including fine-tuning and later modifications); large frontier developer has group revenue above USD 500 million in the prior year (Sec. 1420).
- Large frontier developers must write, follow and publish a frontier AI framework, review it yearly, and publish material changes with reasons within 30 days. All frontier developers must publish a transparency report before or when they deploy a new or substantially modified frontier model; a model card or system card can satisfy this (Sec. 1421).
- Critical safety incidents must be reported to the DFS office within 72 hours of determining one happened (or learning facts that give a reasonable belief it did); imminent risk of death or serious injury must go to an appropriate authority within 24 hours. Large developers send internal-use risk summaries quarterly (Sec. 1422).
- New in New York: large frontier developers must file a disclosure statement with the office before developing, deploying or operating a frontier model in the state, renew it every two years or on a change, and pay a pro rata share of the office's costs (Sec. 1428).
Who it applies to
- Frontier developers and large frontier developers, for frontier models developed, deployed or operating in whole or in part in New York (Sec. 1425).
- Extraterritorial: yes. A model built abroad but offered to or running for New York users falls in scope.
- Exempt: accredited New York colleges and universities doing academic AI research, and the Empire AI Consortium (Sec. 1426).
- Unlike California, the amended text has no whistleblower protection section; the public can report incidents to the office.
Key dates
- S6953B passes Senate (58 to 1) and Assembly
- Delivered to Governor
- Signed as Chapter 699 of 2025 with Approval Memo No. 76
- Chapter amendment S8828 passes Senate
- S8828 passes Assembly
- S8828 signed as Chapter 96 of 2026; Article 44-B replaced with new sections 1420 to 1429
- Act takes effectUpcoming
- First annual DFS office report on critical safety incidentsUpcoming
Full date record
| Date | Event |
|---|---|
| 2025-06-12 | Original bill passes both houses |
| 2025-12-19 | Signed as Chapter 699 of 2025 (Approval Memo No. 76) |
| 2026-03-27 | Chapter amendment S8828 signed as Chapter 96 of 2026 |
| 2027-01-01 | Act takes effect |
| 2028-01-01 | First annual incident report from the office |
Penalties and enforcement
- AG civil penalties against large frontier developers: up to USD 1 million for a first violation and USD 3 million for each later one, for failing to publish or send documents, false or misleading statements, unreported incidents, or not following their own framework (Sec. 1427).
- DFS office: USD 1,000 per day for not filing a disclosure statement or not correcting false information, plus any unpaid assessments (Sec. 1428).
- No private right of action (Sec. 1427).
- Reports to the office are exempt from the state freedom of information law. Redactions for trade secrets, security and public safety are allowed if described, with unredacted copies kept for five years.
- No court challenge to the RAISE Act was found as of 2026-10-19 (limited search). Executive Order 14365 (Dec 2025) created a federal push to contest state AI laws; no action against this Act was found.
What it means for an Indian company
- Same answer as California for most firms: if you build on third-party models and do not train above 10^26 operations, the Act does not apply to you directly.
- Indian foundation model builders serving New York users: one compliance pack can cover both states, but plan for the 72-hour incident clock (California allows 15 days) and the DFS registration and fee.
- Incident playbook: make sure your SC-AI-031 AI incident management and regulator reporting process can classify a "critical safety incident" and file within 72 hours, with a 24-hour path to law enforcement.
- Publish and keep evidence of your framework and transparency reports (SC-AI-014 Model documentation (model cards, system cards), SC-AI-025 Public AI transparency statement and notices, SC-AI-032 Logging and record keeping).
- Weight security and red teaming are framework headings, so align with SC-AI-029 AI-specific security controls (prompt injection, model abuse) and SC-AI-018 Robustness and adversarial testing (red teaming).
- Fintech link: the office sits inside DFS, which already supervises New York banks and insurers. Indian vendors to DFS-regulated firms should expect AI questions to come through that channel too (see NYDFS AI Cybersecurity Letter 2024).
Obligations
Full obligation breakdown coming
We break the most requested policies down into numbered obligations mapped to controls. Leave your details and we’ll tell you when New York RAISE Act is done.
Glossary
- Frontier model: a foundation model trained with more than 10^26 operations.
- Large frontier developer: a frontier developer whose group revenue exceeded USD 500 million last year.
- Chapter amendment: a follow-up bill in New York, agreed with the Governor at signing, that rewrites a newly signed law.
- DFS: New York State Department of Financial Services.
- Disclosure statement: the registration filing large frontier developers must keep current with the office.
- Critical safety incident: events such as stolen model weights causing injury, loss of control, or a model deceiving its developer to escape oversight.
- Empire AI Consortium: New York's public and academic AI computing partnership, exempted from the Act.
Key takeaways
- Signed 19 Dec 2025 (Chapter 699); rewritten by Chapter 96 of 2026 (signed 27 Mar 2026); effective 1 Jan 2027.
- Thresholds mirror California: 10^26 operations and USD 500 million revenue.
- Stricter than California on timing (72-hour incident reports) and adds DFS registration, fees and penalties up to USD 3 million for repeat violations.
- No whistleblower section, no private lawsuits.
- For most Indian companies, a vendor diligence point; for frontier labs, a second state to file with.
Official sources
- S8828 (chapter amendment), NY Senate, accessed 2026-10-19
- S6953B (original RAISE Act), NY Senate, accessed 2026-10-19
This is general information, not legal advice. Last verified 19 Oct 2026 against the official source. Laws change; confirm the current position with qualified counsel before acting.