New York Sets November Registration for Major AI Developers Under RAISE Act

Key Takeaways

• Registration Begins in November: New York will direct large frontier AI developers to register with the state ahead of the RAISE Act’s broader requirements taking effect in January 2027.
• 72-Hour Incident Reporting: Covered developers will be required to report critical safety incidents to the state’s DIGIT Office within 72 hours.
• Regular Risk Assessments Required: Developers must establish public safety and transparency frameworks and submit quarterly assessments of catastrophic risks.
• New York Builds Out DIGIT: Gov. Kathy Hochul appointed Marc Gilman as deputy director for the RAISE Act and the first full-time hire of the state’s new digital governance office.
• Further AI Rules Could Follow: Hochul said her administration will explore additional AI safety measures in the coming months.

Deep Dive

New York will begin directing large frontier AI developers to register with the state in November, giving companies roughly two months to prepare before the central requirements of the state's RAISE Act take effect in January.

Gov. Kathy Hochul announced the timetable Monday as her administration begins putting the machinery behind the Responsible AI Safety and Education Act into place. The law requires covered developers to disclose how they manage safety risks, report critical safety incidents within 72 hours and regularly submit information about potentially catastrophic risks associated with their models.

Beginning in January 2027, companies subject to the law will have to comply with those requirements and report to New York's new Office of Digital Innovation, Governance, Integrity and Trust, or DIGIT.

The office, housed within the New York State Department of Financial Services, was announced earlier this year as part of Hochul's 2026 State of the State agenda. It is meant to give New York a central authority for digital safety and technology governance, an unusually broad mandate for an office sitting within a state financial regulator.

For the largest AI developers, the obligations are substantial. They must establish safety and transparency frameworks and publish them on their websites. Critical safety incidents must be reported to DIGIT within 72 hours and, where required, to other government authorities. Developers must also file quarterly assessments of catastrophic risks, which DIGIT may share with other authorities.

Registration comes with continuing disclosure requirements. Covered developers must file a disclosure statement at least every other year beginning Jan. 1, 2027, and pay assessments under the law.

The reporting does not run in only one direction. Members of the public will be able to submit suspected critical safety incidents to DIGIT. The office may then transmit those reports to other government authorities when appropriate. It will also publish an annual report summarizing the incident reports it receives, its observations about frontier model safety and any changes to the RAISE Act it believes should be considered.

That gives the state something regulators often struggle to obtain with fast-moving technologies: a formal channel for learning about serious problems while they are still recent, rather than months later through litigation, whistleblowers or corporate disclosures.

Hochul is already suggesting the law may be a starting point rather than the finished product. Her administration said Monday that she will explore additional steps in the coming months to strengthen the state's AI safety laws and regulations. It did not specify what those measures might be.

New York Starts Building the Office Behind the Law

A law that demands reports is of limited use without someone there to read them. New York is now staffing the office that will have to do exactly that. Hochul appointed Marc Gilman as deputy director for the RAISE Act, making him the first full-time hire for DIGIT. He will support implementation of the law alongside existing DFS personnel with experience in technology regulation, cybersecurity and AI. Additional full-time staff are expected to join the office in the coming weeks and months.

Gilman previously served as general counsel and vice president of compliance at Theta Lake, where his work included enterprise commercial transactions, intellectual property, regulatory engagement and legal and compliance strategy involving AI, privacy and cybersecurity. He has also served as an adjunct professor at Fordham University School of Law, teaching on the intersection of financial services and technology.

The role carries more weight than its title might suggest. DFS's description of the deputy director position says the official will oversee the team implementing the RAISE Act and its transparency, reporting and disclosure requirements. The advertised salary range was $172,787 to $213,995.

The appointment follows a broader implementation effort Hochul convened after signing the RAISE Act. DFS, the state Office of Information Technology Services and the Division of Homeland Security and Emergency Services are involved.

Attorney General Letitia James, who championed the legislation, said her office intends to enforce it.

“As artificial intelligence advances rapidly, New York is leading the nation in passing safe and responsible laws and regulations to protect our state,” James said. “My office will always enforce the law and do everything in our power to keep New Yorkers safe.”

DFS Acting Superintendent Kaitlin Asrow said the department is building DIGIT while preparing to give the public and law enforcement authorities greater visibility into frontier developers' safety practices and emerging risks.

DIGIT itself extends beyond the RAISE Act. When Hochul proposed the office in January, the administration described it as a central body for digital safety and technological governance, charged with developing new approaches and bringing greater consistency to enforcement across emerging technology issues.

A State-Level Answer to a Federal Fight

Monday's announcement arrived with an unmistakably political argument attached to it. Hochul accused the Trump administration and congressional Republicans of failing to act on AI safety and used the opening of the United Nations General Assembly in New York to call for further action from federal officials and international leaders. Those criticisms are the administration's characterization of the federal response, rather than a provision or finding of the RAISE Act itself.

“Donald Trump and Washington Republicans may be standing still as AI grows more unpredictable, but New York will not,” Hochul said.

The argument over who should regulate advanced AI has become nearly as important as the question of how it should be regulated. New York's answer, at least for now, is not to wait.

State Sen. Andrew Gounardes, who sponsored the RAISE Act in the Senate, described Monday's announcement as an early step in that effort. Assembly member Alex Bores said DIGIT has authority under the law to seek additional information from AI companies, issue rules and recommend legislation as the technology develops.

For companies that fall within the law's definition of large frontier AI developers, however, the immediate question is less philosophical. The calendar is now short. Registration begins in November. The broader compliance regime follows in January. And New York is hiring the people who will be waiting for the reports.

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