New York opens AI safety portal; frontier developers must register by Jan. 1, 2027
For the third-party-risk officer at a regional bank
New York opened a registration portal on Tuesday, and large frontier AI developers such as Anthropic and OpenAI must register on it by January 1, 2027, when the state's RAISE Act takes effect, TechCrunch reported.1
The RAISE Act covers large frontier developers, defined as companies with more than $500 million in annual revenue, and sets safety and transparency duties for them, according to TechCrunch.1 The sources do not say why New York set the revenue threshold at that level; Gov. Kathy Hochul said the state is building "a national model for smart, sensible AI regulation."1
Covered developers must publish safety frameworks on their websites, report critical safety incidents within 72 hours, and issue public model transparency reports, TechCrunch reported.1
The new Office of Digital Innovation, Governance, Integrity, and Trust (DIGIT) will implement the act and oversee the labs; penalties can reach $1 million for one violation and $3 million for subsequent violations.1
The state can also bring enforcement actions against companies that fail to register, though a spokesperson declined to give specifics, according to TechCrunch.1
TechCrunch reported that California's SB 53, in effect since January, requires incident reports within 15 days, and that Illinois' SB 315, effective at the start of 2027, adds independent safety compliance audits.1
The 72-hour incident report goes to the state, and the sources do not say that customers such as banks will receive it. Banks that rely on covered AI vendors may want contract terms requiring the same report on the same timeline, and should note that vendors under the $500 million revenue line are not covered.
Large frontier developers must register on the state portal by January 1, 2027, when the RAISE Act takes effect.1
Our take. From January 1, OpenAI and Anthropic must tell New York about a critical safety incident within 72 hours. Your contract with them may not require them to tell you at all.
Action. Third-party risk: Add AI vendor contract terms requiring access to safety frameworks and notice of critical safety incidents within 72 hours.
What our records say
New York's RAISE Act (General Business Law Article 44-B) binds frontier AI developers rather than banks as users of AI, and it is final with an effective date of January 1, 2027.1 It is a final statute that regulates frontier model developers, with banks covered only if they train a frontier model with more than 10^26 operations, effective January 1, 2027.12
From our records
- New York RAISE Actdocument · final NY DFS, issued Dec 2025 · effective 2027-01-01, Official text
- Claude (Anthropic)vendor · banks using it (24) Goldman, JPMorgan, BankUnited · alternatives Microsoft Copilot, ChatGPT Enterprise, Gemini Enterprise
- ChatGPT Enterprise (OpenAI)vendor · banks using it (17) Morgan Stanley, BNY, Customers Bank · alternatives Microsoft Copilot, Claude, Gemini Enterprise
- California SB 53 (Transparency in Frontier AI Act)document · final State of California, issued Sep 2025 · effective 2026-01-01, Official text