Who does it apply to?

Developers of frontier AI models only (trained with more than 10^26 operations); stricter duties for large frontier developers with annual revenue above $500 million

Deadline tracker · US, New York

Frontier-model developer duties

Q: When does "Frontier-model developer duties" apply?

1 January 2027 (Upcoming). Transparency and reporting on training, deployment, safety protocols and incidents for frontier developers. The chapter amendment signed 27 March 2026 takes effect on 1 January 2027 and sets civil penalties of up to $1 million for a first violation and $3 million for subsequent violations. Not relevant to companies that only use AI.

Transparency and reporting on training, deployment, safety protocols and incidents for frontier developers. The chapter amendment signed 27 March 2026 takes effect on 1 January 2027 and sets civil penalties of up to $1 million for a first violation and $3 million for subsequent violations. Not relevant to companies that only use AI.

Date: 1 January 2027 (in 88 days)
Status: Upcoming
Law: RAISE Act (as amended 27 March 2026)
Jurisdiction: US, New York
Applies to: Developers of frontier AI models only (trained with more than 10^26 operations); stricter duties for large frontier developers with annual revenue above $500 million
Evidence expected: Not applicable to deployers.
Source: Cooley, amended RAISE Act (March 2026)
Last reviewed: 2026-09-21
Calendar: Add this date (.ics) · Google Calendar · subscribe to all dates

What to do

Check whether it applies to you with the readiness scan.
Record the obligation against each affected system in your AI inventory.
The Compliance Kit holds the document that produces the evidence for this row.

Get an email before each date

One email 30 days and one 7 days before each date in the markets you tick, with who it applies to and what to have ready. Next: Frontier-model developer duties, 1 Jan 2027.

Cite this

Dutybound, "Frontier-model developer duties", AI regulation deadline tracker, reviewed 2026-09-21, https://getdutybound.com/deadlines/us-ny-raise/. Primary source: https://www.cooley.com/news/insight/2026/2026-03-31-new-yorks-frontier-ai-law-gets-a-california-makeover-with-some-key-differences.