top of page
Search

New York Passes Landmark AI Transparency Law - HR ALERTS

New York Passes Landmark AI Transparency Law: What Employers Should Know

Effective: December 19, 2025

New York has enacted the Responsible AI Safety and Enforcement (RAISE) Act, signed into law by Governor Kathy Hochul on December 19, 2025, a first-of-its-kind law focused on transparency and safety for large “frontier” AI model developers. While the law has received significant attention, most employers will not have new compliance obligations at this time.


What the RAISE Act does

The law requires large AI model developers to:

  • Publish information about their AI safety and risk-mitigation protocols

  • Report incidents involving “critical harm” to the state within 72 hours

  • Comply with oversight by a new AI office within the New York Department of Financial Services

Penalties for non-compliance apply to developers, not employers.


What this does not do

  • It does not regulate employer use of AI tools

  • It does not impose new HR, hiring, or reporting requirements on employers

  • It does not apply to most businesses using off-the-shelf AI products


How this compares to Colorado’s AI law

  • New York (RAISE Act): Targets large AI model developers and focuses on transparency and incident reporting.

  • Colorado AI Act: Regulates high-risk AI systems used in consequential decisions and applies to both developers and deployers, including employers using AI in areas like hiring, promotion, or performance management.

In short, Colorado’s law is more likely to directly impact employers, while New York’s RAISE Act is aimed at upstream AI developers.


Why this still matters to employers

Together, these laws signal a clear trend: AI is no longer unregulated. Employers should expect continued state-level activity and focus on responsible AI use, human oversight, and clear internal guidelines.


Vida HR will continue monitoring AI-related legislation and will notify clients if any employer-specific obligations emerge.

 

Get day-to-day updates on New York Passes Landmark AI Transparency Law visit the Vida HR Knowledge Center (Vida HR Clients Exclusive).

Comments

bottom of page