New York continues to be a leader in establishing a regulatory framework for artificial intelligence. Recent legislative actions and executive proposals aim to balance technological innovation with robust protections for workers and consumers. Central to these updates are the Responsible AI Safety and Education (RAISE) Act and a series of new initiatives from Governor Kathy Hochul’s 2026 State of the State.
The RAISE Act: Regulating Frontier AI
The RAISE Act (Assembly Bill A6453) targets the most advanced “frontier” AI models to prevent catastrophic harm, defined as incidents causing significant loss of life or billions in property damage.
Key provisions include:
- Large Developer Obligations. The Act applies to developers with aggregate computing costs exceeding $100 million.
- Safety Protocols and Audits. Covered developers must implement formal safety measures and undergo annual independent audits.
- Rapid Incident Reporting. Organizations must report “safety incidents” that create material risks of critical harm to the Division of Homeland Security and Emergency Services within 72 hours of learning of the incident or obtaining sufficient facts to reasonably believe one occurred.
- Whistleblower Protections. The law protects individuals who report safety violations or non-compliance from employer retaliation.
Governor Hochul’s 2026 AI and Digital Initiatives
Building on existing regulations, Governor Hochul has also unveiled a new suite of proposals designed to enhance digital safety and transparency.
- Office of Digital Innovation, Governance, Integrity & Trust (DIGIT). This first-of-its-kind office will serve as a central authority for digital safety, ensuring consistent enforcement of technological governance.
- AI Transparency and Labeling. New legislation will require AI-generated content to include “provenance data”, labels that act as a digital nutrition label to help the public identify deepfakes and manipulated media.
- Election Integrity. To protect democratic processes, the Governor is proposing a ban on non-consensual deepfakes of candidates during specified periods leading up to elections.
- Data Broker Accountability. Proposed rules would require data brokers to register with the State and allow New Yorkers to submit a centralized request to have their personal data deleted.
Implications for Employers and HR Professionals
These updates signal a shift toward heightened corporate accountability regarding AI. While the RAISE Act focuses on large-scale developers, the broader transparency and data privacy mandates will affect how all New York businesses acquire and deploy AI tools.
Next Steps for Employers
To navigate this evolving regulatory landscape, organizations should take the following proactive steps:
- Evaluate AI Infrastructure: Determine whether your organization or its vendors develop models that meet the RAISE Act’s high compute-cost thresholds.
- Verify Content Labeling: Review marketing and communication workflows to ensure that any AI-generated content is properly labeled in anticipation of new transparency requirements.
- Audit Data Privacy Practices: If your organization utilizes third-party data for recruiting or marketing, review those vendors for compliance with emerging data broker regulations.
- Update Compliance and Whistleblower Policies: Ensure internal policies protect employees who raise concerns about AI safety or ethical use, aligning with the RAISE Act’s anti-retaliation provisions.
- Stay Informed: Monitor guidance from the newly formed DIGIT office and the Attorney General for specific implementation timelines.
