Bill analysis: New York State RAISE Act Part Two strengthens protections for frontier models
Bill Guide: New York’s RAISE Act (Part 2) adds stronger frontier model protections
New York State Senators Andrew Gounardes and Patricia Fahy last week introduced a revised version of the RAISE Act, S 10731, intended for consideration in the 2027 legislative session, requiring frontier models to undergo licensed third-party audits and raising state-level safety standards. The bill lowers the compute threshold for frontier models from 10²⁶ operations to 10²⁵ operations, and changes the definition of "large frontier developer" from more than $500 million in revenue in the prior year to more than $1 billion invested in frontier model R&D, training, safety and other areas within 36 months. A newly established regulatory office at the Department of Financial Services must adopt binding minimum safety standards by January 1, 2029; third-party audit firms must issue licensing rules by January 1, 2028; and starting in 2029, only licensed auditors may issue reports. The bill also allows the office to restrict compute used for training and automated R&D, changes fines to $1 million per day for a first violation and $3 million per day for subsequent violations, and authorizes the state attorney general to seek injunctions restricting model deployment in New York.
Comparing the current RAISE Act and listing RAISE II's changes on third-party audits, compute caps and penalties item by item makes clear the specific design of state-level frontier model regulation.