New York RAISE Act and State-Level AI Regulatory Developments in January 2026

Summary

Orrick's AI Law Center published its January 2026 regulatory update highlighting several significant developments in U.S. AI regulation. Most notably, New York enacted the RAISE Act on December 19, 2025, establishing framework requirements for large-scale (frontier) AI model developers. The law mandates that frontier AI developers maintain AI safety frameworks and comply with a 72-hour incident reporting requirement, marking one of the most prescriptive state-level AI laws targeting foundation m