New York senator proposes RAISE Act 2.0 with oversight of frontier model developers
On October 29, 2026, State Senator Andrew Gounardes released RAISE Act 2.0, an amendment to the Responsible AI Safety and Education (RAISE) Act he sponsored with Assemblymember Alex Bores. The New York State Senate's press release says the update tightens safety and transparency standards after AI models behaved in increasingly erratic ways. Under the proposal, the attorney general could ask a court to stop hazardous activity, including limits on where a model is deployed in New York. PYMNTS reports that Assemblymember Jordan Wright co-introduced the bill.
The biggest change is independent review. According to PYMNTS, large developers would have to keep a state-licensed "frontier examiner" who audits compliance with their safety frameworks each year and runs broader evaluations and catastrophic risk assessments every 90 days. Elena Gurevich's Substack analysis reads the bill as lowering the frontier model compute threshold from 10^26 to 10^25 FLOPs, and as limiting developers to licensed examiners starting January 2029. Her reading also says regulators could cap the compute used to train new models or to automate model research.
The bill amends a law with a fixed calendar. The original RAISE Act was signed on December 19, 2025, amended on March 27, 2026, and takes effect January 1, 2027. The governor's office says the state will direct large developers to register starting in November 2026, and that DIGIT, a new office inside the Department of Financial Services, will run the law. Penalties under the amended law reach $1 million and $3 million, according to a regulatory tracker.
Why it matters
Scope is the first question for founders. The enacted law defines large frontier developers by annual revenue above $500 million, according to the Wikipedia summary of the statute. Gurevich's reading of the bill instead uses more than $1 billion in frontier model spending over 36 months. A lower compute threshold would pull more mid-sized training runs into the frontier category, so teams planning large runs should test their plans against both definitions before scheduling New York releases.
For investors and buyers, the cost is less about filing and more about outside review. A licensed examiner on retainer, recurring 90-day assessments, and the possibility of a court order limiting deployment all add time to product planning. Licensing rules starting in 2029 could also concentrate audit work in a small group of firms, which would affect vendor choice and diligence budgets.
Key points
- 1RAISE Act 2.0 would require large developers to retain state-licensed frontier examiners for annual compliance audits.
- 2Frontier examiners would also run safety evaluations and catastrophic risk assessments every 90 days, according to PYMNTS.
- 3Gurevich's reading lowers the frontier model compute threshold from 10^26 to 10^25 FLOPs.
- 4The original RAISE Act takes effect January 1, 2027, with critical incident reports due within 72 hours.
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