New York to require AI developer registration under RAISE Act

New York moves forward with AI developer oversight

New York will begin requiring major artificial intelligence developers to register with the state this November, Governor Kathy Hochul announced Monday, as the state prepares to implement the Responsible AI Safety and Education (RAISE) Act ahead of its January 1, 2027 effective date.

The law establishes transparency, safety, and reporting requirements specifically for developers of the most computationally intensive AI models. Companies generating more than $500 million annually face additional obligations, including mandatory reporting of serious safety incidents within 72 hours and public disclosure of how they assess and mitigate catastrophic risks.

According to AM New York, which first reported the announcement, Hochul also raised the possibility of exploring "AI kill switches" as the state considers building on the existing legislation.

Why it matters

New York's approach represents one of the most concrete state-level regulatory frameworks for frontier AI development in the United States. The registration requirement and incident reporting mandate create enforceable accountability mechanisms at a time when federal AI regulation remains largely aspirational. For AI companies operating at scale, compliance with state-by-state requirements may become a significant operational consideration.

Enforcement and potential expansion

Attorney General Letitia James holds authority under the RAISE Act to pursue civil penalties reaching $1 million for initial violations of certain requirements and up to $3 million for subsequent violations. Hochul indicated Monday that penalty amounts could be increased if they prove insufficient as deterrents.

James announced her office is already monitoring the AI industry and encouraged workers with knowledge of potential violations involving cybersecurity, data privacy, or fraud to use the attorney general's whistleblower portal.

The governor made clear that additional AI legislation may follow in the next legislative session. State Senator Andrew Gounardes, who sponsored the RAISE Act, pointed to two bills he introduced earlier this year that would expand oversight: one requiring annual independent third-party audits of whether developers comply with their own safety frameworks, and another directing the state Office of Digital Innovation, Governance, Integrity and Trust (DIGIT) to establish minimum standards for those frameworks.

Implementation timeline and staffing

Hochul announced that Marc Gilman has joined DIGIT as deputy director overseeing RAISE Act implementation. The office operates within the state Department of Financial Services and is currently building out its staffing and enforcement mechanisms.

When pressed on whether she regretted amendments that critics argued weakened the original legislation, Hochul defended the law while acknowledging "there was always room to do more." She characterized the kill switch concept as preliminary, stating "all options are on the table" as the administration researches possible safeguards.

The registration requirement beginning in November will give the state nearly 14 months to establish its oversight infrastructure before the law's substantive requirements take effect at the start of 2027.

Details were first reported by AM New York.