New York RAISE Act Explained: Who It Covers and When It Starts

Short answer: no, the New York RAISE Act is not in force yet. It takes effect on January 1, 2027. The Responsible AI Safety and Education (RAISE) Act covers frontier developers, which are companies that train the very largest AI models. The governor signed it on December 19, 2025. A chapter amendment, which is a follow-up law that edits one already signed, then rewrote it. The governor signed that on March 27, 2026. The state's own code text and announcements treat the amended version, starting January 1, 2027, as the law.

The heaviest duties fall on "large frontier developers," those with over $500 million in yearly revenue. The attorney general (AG) enforces it, with fines up to $1 million for a first violation and $3 million for each later one. This is not legal advice. Check the current text before you rely on it.

TL;DR

• Status on October 5, 2026: signed, amended, and not yet effective. The official start is January 1, 2027. On September 21, 2026, New York said large developers will be directed to register starting in November.
• The bill did not change between passage and signing. It was signed as passed. A chapter amendment then changed it. Guides that describe the December version describe text the state no longer treats as the law.
• Who: developers who trained a model with more than 10^26 operations (a count of basic computer arithmetic steps). Large ones, over $500 million in revenue, carry the penalty.
• Enforcement: the AG sues. A new office in the Department of Financial Services (DFS) takes reports and sets fees. The text creates no private right to sue.
• California's Senate Bill (SB) 53 is close in design but started a year earlier. A table below compares them.

Why you see two different versions

Most coverage of this law dates from December 2025 or January 2026. That is before the chapter amendment became law. Some of it still describes the signed version. That version had a test based on $100 million spent on computing power, and fines up to $10 million. The final version has a $500 million revenue test and fines up to $3 million. A search for the "New York RAISE Act" mixes the two.

A statute is a law passed by a legislature. A session law is the text of a bill as signed. The code is the organized set of statutes. Here the code is the General Business Law (GBL), Article 44-B, sections 1420 to 1429. For how the two relate, see what a session law is.

New York RAISE Act effective date and key dates

The dates come from the Assembly's bill records, Chapter 699 of 2025, Chapter 96 of 2026, and the DFS announcement of September 21, 2026.

• June 12, 2025: the Senate and Assembly passed S6953-B and A6453-B. Both houses passed it that day, according to the Assembly's bill record.
• December 19, 2025: the governor signed it as Chapter 699 of the Laws of 2025. The signed text said it would take effect "on the ninetieth day after it shall have become a law."
• January 6 and 8, 2026: the chapter amendment was introduced as A9449 and S8828.
• March 11, 2026: the Assembly passed the chapter amendment. The Senate had passed it on January 28.
• March 27, 2026: signed as Chapter 96 of the Laws of 2026. Section 3 of the amendment swaps the signed start clause for "January 1, 2027." The old clause read "on the ninetieth day after it shall have become a law."
• September 21, 2026: the governor and DFS announced implementation steps. "Starting in November, New York will direct large frontier AI developers to register with the State." They also named the new office inside DFS. It is the Office of Digital Innovation, Governance, Integrity and Trust (DIGIT).
• January 1, 2027: the law takes effect. Large developers must file a disclosure statement, "at least every other year, starting January 1, 2027," says the release.
• January 1, 2028: the DFS office's first annual public report is due (GBL § 1422(7)).

The amendment replaced the whole article. Section 2 of Chapter 96 says the article "is REPEALED and a new article 44-B is added." The amended article is the one in the state's code.

One timing point needs care. The December text had a 90-day start, which would have fallen on March 19, 2026. The amendment passed the Legislature on March 11 and was signed on March 27. The Senate's code text marks Article 44-B "Effective January 1, 2027," and the September 2026 release says "Beginning January 2027." I found no source that treats any earlier date as the start. If the gap between those dates matters to you, ask a lawyer.

What the amendment changed

This guide compares both versions on the Assembly's site. Here is what moved.

• Who is "large." As signed: a developer that had spent over $100 million on computing power. As amended: yearly revenue over $500 million.
• Model line. As signed: over 10^26 operations and over $100 million in computing cost. As amended: over 10^26 operations.
• Safety document. As signed: a "safety and security protocol." As amended: a "frontier AI framework."
• Ban on release. As signed: a large developer could not deploy a model if that "would create an unreasonable risk of critical harm." As amended: no such ban.
• Harm measure. As signed: 100 or more people, or $1 billion. As amended: more than 50 people, or $1 billion.
• Incident reports. As signed: to the AG and a state security agency, in 72 hours. As amended: to a DFS office, in 72 hours.
• Top fine. As signed: $10 million, then $30 million. As amended: $1 million, then $3 million.
• Start. As signed: 90 days after signing. As amended: January 1, 2027.

Who it covers

Section 1420(9)(a) defines a "frontier model" as "a foundation model that was trained using a quantity of computing power greater than 10^26 integer or floating-point operations," meaning a very large count of basic calculations done during training. A foundation model is a general-purpose AI trained on broad data. A "frontier developer" is a person who trained, or began training, such a model.

Section 1420(10) defines a "large frontier developer." Its yearly revenue, with its affiliates (related companies under common control), must be "in excess of five hundred million dollars" in the preceding year. Section 1425 limits the article to frontier models "developed, deployed, or operating in whole or in part in New York state." Section 1426 exempts colleges doing academic research. It also exempts the Empire AI consortium.

The 10^26 line is extremely high and aimed at frontier model builders. If you only use someone else's model, these duties sit with the builder. A startup that builds an app on a vendor's model is a user. The lab that trained the model is the developer.

What it requires

• A published safety framework. A large frontier developer must publish a "frontier AI framework." It must "describe in detail" how the developer handles risk testing, safeguards, security and incident response. The developer reviews it every year (§ 1421).
• A report with each release. Any frontier developer must post a transparency report before or with a new model. Large ones add summaries of their risk checks (§ 1421(3)).
• Incident reports in 72 hours. A "critical safety incident" is serious harm. One example is a model escaping its maker's control and causing death or injury. A frontier developer must report one to the DFS office "within seventy-two hours" (§ 1422(3)). The clock starts when it determines the incident happened, or learns facts that give a reasonable belief. If an incident poses an imminent risk of death or serious injury, the developer must tell the right authority within 24 hours.
• Registration and fees. A large frontier developer needs a current disclosure statement on file with the office. It must also pay its share of the office's costs (§ 1428). The statement is renewed every two years, or sooner if an important fact changes.
• No false statements. A frontier developer may not make a materially false or misleading statement about catastrophic risk (§ 1421(4)). That means a risk of more than 50 deaths or serious injuries, or over $1 billion in damage, from one incident (§ 1420(3)).

New York RAISE Act penalties and enforcement

Section 1427(1) lets the attorney general "bring a civil action to recover a civil penalty." A civil action is a lawsuit in court. A civil penalty is a fine paid to the state. The cap is "one million dollars for a first violation" and "three million dollars per subsequent violation." It applies when a large frontier developer fails to publish a required document, makes a false statement, fails to report an incident, or breaks its own framework.

Section 1428(5) adds a separate fine run by the DFS office. It is "one thousand dollars for each day" a large developer fails to file its disclosure statement. The office adds unpaid assessments, after notice and a hearing.

On private lawsuits the text is direct. Section 1427(2) says: "Nothing in this article shall be construed to establish, authorize or create a private right of action associated with violations of this article." A private right of action is a right for a private person or company to sue under the law. The article has no whistleblower section.

Section 1429 lets the office write rules. The September 2026 release says the governor is also "exploring ways to build on the RAISE Act." The article can change again.

How it compares with California's SB 53

The two laws share definitions almost word for word. They differ in speed, reporting and who gets the reports. California's SB 53 is Chapter 138 of the Statutes of 2025, approved September 29, 2025. It sits in Business and Professions Code sections 22757.10 to 22757.16, and the table follows that signed text. For the California side, see California AI laws explained.

What a business should check

1. Find out whether you trained a model above the 10^26 line, or plan to. If not, you are a user.
2. If you use a vendor's model, ask which of its duties under this law and SB 53 it says it meets. Ask for the framework link. A startup that builds on a vendor's model usually does not file anything itself. The lab that trained the model does.
3. If you are a large frontier developer, watch for the DIGIT registration notice this November.
4. Put January 1, 2027 on your calendar for the first disclosure statement.
5. Check the Assembly or Senate bill page and DFS every quarter. Rules can still come.

What goes wrong

The common mistake is citing the December 2025 version. Its $100 million test, 100-person harm line and $10 million fine are gone. The next is treating the signing date as the start date. The law starts January 1, 2027. The last is assuming a user of a big model is covered. The article reaches builders at the frontier.

For another state's approach, read the Colorado AI law guide. To cite New York sections correctly, see how to find and cite New York law.

Where to read the official text

The Assembly's pages show each version and its history. The September 21, 2026 facts above come from the DFS announcement of that date. Here are the pages: A6453-B, the bill as signed, and A9449, the chapter amendment. The DFS announcement of September 21, 2026 covers registration. The current code text is on the New York Senate's laws site under General Business Law sections 1420 to 1429.

This guide is part of US Law Data: The Complete Guide, a map of where US law comes from and how to use it.

FAQ

Is the New York RAISE Act in effect? Not yet. It was signed and then amended. The state's code text and its September 2026 release put the start at January 1, 2027.

What is the RAISE Act effective date? January 1, 2027. The first signed text said 90 days after signing. The March 27, 2026 amendment replaced that with the January date.

Who does the RAISE Act apply to? Frontier developers, meaning companies that trained a model with more than 10^26 operations. The fines and the registration duty fall on large frontier developers with over $500 million in revenue. If you only use another company's model, the main duties sit with the builder.

What are the penalties? The attorney general can seek up to $1 million for a first violation and up to $3 million for each later one. The DFS office can add $1,000 per day for a missed disclosure filing.

Can someone sue me under it? The text says nothing in the article creates a private right of action. Only the attorney general sues for the penalty.

How is it different from California's SB 53? New York starts a year later. It gives 72 hours to report an incident, where California gives 15 days. It adds registration and fees. It has no whistleblower section.

Does it apply if I just use an AI model? Usually the main duties sit with the company that trained the model, not the business that only uses it.

If your product needs current US statute and regulation text, with its amendment history, see the US primary law API, a data feed that software can read.

Priyansh Khodiyar

Co-Founder & CTO

Priyansh leads engineering and AI at Vaquill AI: the pipelines that pull statutes, regulations and court rules from every US jurisdiction's official publisher, and the REST API, MCP server and open dataset that serve them.