Bottom line: New York RAISE Act registration opens this month. Starting in November 2026, large frontier AI developers doing business in the state must register with the Department of Financial Services’ new DIGIT office, Governor Kathy Hochul’s administration announced on Sept. 21, with substantive compliance, disclosures and quarterly reporting following on Jan. 1, 2027.
It is the first state-level registration regime for frontier developers in the United States: paperwork season for the labs building the systems everyone else is busy debating.
Who must complete New York RAISE Act registration
As reported from the RAISE Act amendment bill text (S8828/A9449):
- Large frontier developer: annual gross revenue above $500 million in the preceding calendar year, counted together with affiliates.
- Frontier model: a foundation model trained with more than 10^26 integer or floating-point operations.
- The regime applies to covered entities doing business in New York, wherever they are headquartered, and the final enacted wording should be confirmed with counsel before anyone relies on the thresholds.
November opens the portal, January opens the obligations
- November 2026: registration through a state portal run by the Office of Digital Innovation, Governance, Integrity and Trust (DIGIT), housed at DFS. No exact start date, forms or fees have been published yet.
- Jan. 1, 2027: disclosure statements, transparency and safety standards, and regular reporting to DIGIT come into force.
- 72 hours: the window in which covered developers must report critical AI safety incidents to the state.
The kill-switch question
Hochul also floated an AI ‘kill switch’ that could let the state order a model shut down. No process, trigger or legal authority has been outlined, and the idea remains under consideration, but it is now part of the same conversation as a registration portal, which is a new entry in the annals of regulatory subtext.
Why it matters beyond New York
State regimes tend to beget state regimes. A 72-hour incident-reporting clock and quarterly reporting cadence set here become the compliance benchmark other states can copy, just as New York’s financial regulation routinely becomes the de facto national standard. The timing also lands against a federal backdrop where the White House has directed executive-branch language toward ‘Super Intelligence’ terminology and the UK’s ICO is extending its scrutiny from foundation models to AI agents. Registration in November is the quiet opening act; January is when the obligations get loud.
Officials: Office of Governor Kathy Hochul; supervisor: New York Department of Financial Services, which houses DIGIT.
