New York Opens Registration for Frontier AI Developers

New York has started signing up the companies that build the most powerful AI systems. This month the state opened the registration process required under its Responsible AI Safety and Education Act, known as the RAISE Act, moving a measure that passed last year into the phase where developers have to file real paperwork. The law itself takes full effect on 1 January 2027.

The rules apply to a narrow group. Only large frontier developers, defined as companies with more than $500 million in annual revenue that train models above a set compute threshold, fall under the act. That captures the handful of labs at the front of the field, among them OpenAI and Anthropic, while leaving smaller firms and academic groups outside. Governor Kathy Hochul had signalled the timing back in September, when she announced that the state would direct large developers to register ahead of the compliance deadline.

Registration is the opening requirement, not the whole of it. A covered developer has to keep a current disclosure statement on file, publish a safety and security framework describing how it tests for and manages catastrophic risk, and report critical safety incidents to the state within 72 hours. The law defines those incidents broadly enough to include a model behaving dangerously or a theft of model weights. Oversight sits with a new office inside the New York Department of Financial Services, the same regulator that supervises the state's banks and insurers.

New York is the second state to reach this point, and the comparison with California is deliberate. California's SB 53, signed earlier in the year, set a similar template of transparency reports and incident disclosure, and the RAISE Act borrows much of its structure while differing on who is covered and how penalties work. Together the two states have built a patchwork that national developers now have to navigate, a point worth holding next to the federal government's own move to stand up a super intelligence task force. Abroad the direction is the same, with Australia building a safety regulator with the power to levy penalties.

The open question is enforcement. The new office is still being staffed, and the exact mechanics of filing have been slow to appear, which has left compliance teams reading draft guidance and waiting for the forms. A law that can impose fines is only as strong as the body meant to collect them, and New York now has roughly seven weeks before the January deadline to show that the registration desk is more than a mailbox.