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New York's governor and financial regulator have announced that large frontier AI developers will be directed to register with the state from November under the RAISE Act, with compliance to begin in January 2027
The release announces a timetable and a staffing appointment and itself creates no duties. It gives no filing instructions, and we did not check whether registration materials exist beyond it, so a compliance team has dates to plan against and a statute to read.
Bottom line: An announcement, not a rule; the release itself creates no duties. It sets out a timetable and a staffing appointment, points to no rule text or registration portal, and names no November date. We did not independently check whether DFS has published either elsewhere.
Who this affects: General counsel and compliance leads at frontier AI developers, AI safety and policy teams that would handle incident reporting, and New York regulatory counsel advising developers on RAISE Act registration.
Issue date: 21 September 2026. Issued by the Governor's office and published by DFS as press release pr20260921.
What changed: The state says that starting in November it will direct large frontier AI developers to register and prepare for compliance, and that compliance begins January 2027. Marc Gilman was appointed Deputy Director for the RAISE Act in the DIGIT office.
Analysis: The duties the release lists are the administration's summary of the Act. We read the release, not the statute, so thresholds, penalties and the commencement mechanics are unverified here.
Primary sources: DFS press release pr20260921, 21 September 2026
- Instrument (EN)
- Governor and DFS announcement on implementing the Responsible AI Safety and Education (RAISE) Act
- Authority
- Office of Governor Kathy Hochul; New York State Department of Financial Services (DFS) and its Office of Digital Innovation, Governance, Integrity and Trust (DIGIT)
- Jurisdiction
- New York State
- Status
- Announcement only. The release describes the RAISE Act as signed into law and cites no implementing rule text or registration mechanism; we did not check whether any has been published elsewhere
- Bindingness
- The release itself creates no duties. Any duties come from the Act, which we did not read
- Issue date / next deadline
- Announced 21 September 2026. Registration direction from November, no day given. Compliance from January 2027, per the release
- Document
- DFS press release pr20260921. Upgrade trigger: DFS rule text / registration portal
- Primary source
- https://www.dfs.ny.gov/reports_and_publications/press_releases/pr20260921
What the release announces
The release, on the administration's account, announces three things. Starting in November, New York will direct large frontier AI developers to register with the state and prepare for compliance. From January 2027, the release says, AI companies "will be required to comply" and to provide regular reporting to DIGIT, the office established within DFS. And Marc Gilman has been appointed Deputy Director for the RAISE Act. None of it is a rule. The release gives no November date, no registration form or portal, and no citation to any regulation. It describes a direction the state intends to give. It does not say registration is open, and we have seen no portal.
The Governor also said she will explore ways to build on the RAISE Act in the coming months. The release does not say what that would involve.
The duties the release attributes to the Act
The release lists four things the RAISE Act requires of large frontier AI developers. We report them as the release states them, and we did not open the statute. On the release's account, once compliance begins developers would need to publish safety and transparency frameworks on their websites; report critical safety incidents to DIGIT within 72 hours, and to other authorities as required; file quarterly assessments of catastrophic risks with DIGIT; and register with DIGIT, file a disclosure statement at least every other year starting January 1, 2027, and pay assessments.
The disclosure statement is due "at least every other year", which is a floor and not a fixed two-year cycle. And the release says "assessments". It gives no fee schedule or amount, and we do not turn the word into fees.
The release also says the Act lets members of the public file suspected critical safety incident reports with DIGIT, and that DIGIT will publish an annual report covering incident reports, observations on frontier model safety and any recommended changes to the Act.
What the release does not give is a definition of who counts as a large frontier AI developer. It states no threshold and no penalty. Both questions turn on the statute.
Two January references that are not the same
January 2027 appears twice, and the references differ. One is a compliance start: from January 2027, the release says, companies will be required to comply and report. The other is tied only to the disclosure statement, "starting January 1, 2027". Neither shows that the whole Act commences on 1 January 2027. We give no commencement date for the Act, because the release does not state one and we did not read the enacting text.
The November reference is less precise. The release gives no November day and no registration mechanism, so on its face it sets no deadline.
Marc Gilman, and what his title covers
The body of the release says Gilman was appointed New York's Deputy Director for the RAISE Act, joining the DIGIT office, and that he is DIGIT's first full-time hire. One of the release's sub-headlines calls the post Deputy Director of the state's new DIGIT office. We use the body's wording and do not describe him as the head of DIGIT.
According to the release, he was previously General Counsel and VP of Compliance at Theta Lake, Inc., and has taught as an adjunct professor at Fordham University School of Law. It says more full-time staff will join DIGIT in the coming weeks and months, alongside DFS staff already working on implementation.
What the announcement does not reach
DIGIT sits inside DFS, the state's financial services regulator. Nothing in the release applies the developer duties to banks, insurers or other DFS-regulated firms on that account. The duties it describes attach to large frontier AI developers.
It is also a separate matter from the DFS industry letter of May 2026 on frontier AI cybersecurity risk for regulated financial entities, which we covered earlier. The release does not refer to that letter or amend it.
Assemblymember Alex Bores, quoted in the release, said the law gave DIGIT power "to demand more data from AI companies, issue new rules, and recommend new legislation as the technology evolves". That is a legislator's description of the statute. The release cites no rule issued under that power, and we did not check whether any exists.
What we did not verify
What we opened: the DFS publication of the release, pr20260921, and the Governor's own posting of it. Direct requests from our side to both sites returned a bot-challenge page, so we retrieved both through a web-scraping service on 24 September 2026 and read them in full as text. Their body paragraphs, date and quotations are the same; the Governor's page adds a dateline, a pull quote and media embeds. We link the DFS copy.
What we did not open: the RAISE Act itself, any chapter amendment, any DFS regulation, guidance or registration material, and the State of the State materials on DIGIT. We did not search for DFS rule text or a registration portal beyond the release, which cites neither. Their publication is the trigger for upgrading this piece.
What we refuse to claim: we do not say registration is open, or that a November filing deadline binds anyone. We do not say the whole Act takes effect on 1 January 2027. We do not present the release's list of duties as independently verified law, and we state no threshold, penalty or fee. We do not say DFS-regulated financial firms take on developer duties. The release's own superlatives about New York's law are its words, not ours. Quotations are reproduced with ASCII punctuation in place of the typographic apostrophes used in the release, which is a house typesetting convention and not a change to any word.
Informational analysis for working professionals, not legal advice. Confirm how any rule applies to your situation with qualified counsel.
If you advise a frontier developer, put two dates in the plan: a registration direction expected from November and compliance from January 2027, both on the administration's word. For thresholds, forms and assessment amounts, check the enacted statute and any current DFS materials now, because the release supplies none of them and we examined neither.
Source File
https://www.dfs.ny.gov/reports_and_publications/press_releases/pr20260921
Open the DFS release and confirm three things: the November registration sentence and the January 2027 compliance sentence in the second paragraph, the four-item list of what the release says the Act requires, and the wording of Gilman's title in the body text.
Beginning January 2027, AI companies will be required to comply with those strict standards and provide regular reporting to the state's new Office of Digital Innovation, Governance, Integrity and Trust (DIGIT) established within the New York State Department of Financial Services (DFS). ยท Governor Hochul and DFS press release pr20260921, second paragraph, 21 September 2026
FAQ
Is RAISE Act registration open now?
The release does not say so. It says that starting in November the state will direct large frontier AI developers to register. The release gives no November day, form or portal; we did not independently verify whether registration materials are available.
When do the RAISE Act duties apply?
According to the release, compliance starts in January 2027, and the first disclosure statement is tied to January 1, 2027. The release gives no commencement date for the Act as a whole, and we did not read the statute.
Does this affect banks and insurers regulated by DFS?
Not on the face of the release. DIGIT sits within DFS, but the duties the release describes attach to large frontier AI developers.
Who is Marc Gilman?
The release body names him Deputy Director for the RAISE Act in the DIGIT office and DIGIT's first full-time hire. He was previously General Counsel and VP of Compliance at Theta Lake, Inc.
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