New York to Regulate “Frontier AI” with RAISE Act

New York has a new AI law coming into effect this year. On December 19, the Governor of New York signed the Responsible AI Safety and Education (RAISE) Act. This law regulates large AI developers creating and deploying “frontier models” in whole or in part in the state of New York. These developers will be subject to development and disclosure requirements that act as safety guardrails. A recent Norton Rose Fulbright memo discusses the requirements:

“The RAISE Act requires those large developers of frontier models to do all of the following before deploying a frontier model:

• Implement a written set of safety and security protocols.
• Retain an unredacted copy of the those protocols, publish a redacted copy of those protocols, transmit that redacted copy to the New York Attorney General and New York Division of Homeland Security and Emergency Services, and grant access to those protocols upon request.
• Record and maintain information on tests and test results used in assessing the frontier model’s safety and security.
• Implement safeguards to prevent unreasonable risk of critical harm.”

The memo also notes that these obligations extend to purchasers of such frontier models. This means that companies procuring covered models will be required to comply with RAISE Act requirements. The memo notes:

“The RAISE Act also assigns these ‘large developer’ obligations to anyone that receives the frontier model from the original developer, if full intellectual property rights are transferred and none are retained by the original developer, meaning a company cannot avoid these obligations or penalties by simply buying a completed frontier model or creating an acquisition structure around the RAISE Act.”

The RAISE Act is designed to cover only the largest developers and AI models, but it marks another AI governance law at the state level. It’s unclear whether the RAISE Act will be targeted by the federal government’s “AI litigation team” as part of federal deregulatory efforts. For now, AI companies should assess whether they qualify as “large developers” within the scope of the law. The RAISE Act comes into effect on March 19, 2026, and in-scope companies should prepare for compliance.