AI Law Center January 2026 Updates
In this month’s update, we explore significant developments in the AI regulatory landscape, featuring three essential topics to consider:
1. New York’s AI Law Requirements for Frontier Model Developers
On December 19, New York enacted the RAISE Act, which establishes a framework for large AI developers. This law mandates specific requirements for frontier AI frameworks, including a 72-hour incident reporting obligation. Violations can incur penalties amounting to millions, underscoring the importance of compliance.
2. Responses from State Attorneys General
A bipartisan coalition of 24 state Attorneys General has voiced opposition to potential federal preemption of state AI regulations. They cite concerns related to the Tenth Amendment and highlight states’ roles as primary responders to consumer complaints. Additionally, the Attorney General Alliance has initiated an AI Task Force focused on these pressing issues.
3. Startups and the EU AI Act
As the EU AI Act obligations come into effect, startups must be aware of their responsibilities. The Act includes provisions for AI literacy for various stakeholders, including providers, users, importers, and distributors. This is crucial for navigating the evolving AI landscape.
New U.S. State AI Laws by AI Scope
For those interested in viewing AI laws by state or effective date, our U.S. AI law tracker now offers advanced search and filtering capabilities. This tool allows users to filter over 160 state AI laws by criteria such as state, effective date, or AI scope (e.g., healthcare, deepfakes, government use).
Recent enactments and substantial updates in state AI laws include:
AI in Employment
New Jersey has implemented rules regarding Disparate Impact Discrimination (N.J.A.C. 13:16).
AI in Government
New York has expanded the LOADinG Act (Legislative Oversight of Automated Decision-Making in Government), recently amended by S7599C.
AI in Real Estate
Wisconsin has introduced the Advertising Enhanced by Technology Law (Wis. Stat. § 452.136(1m)).
Frontier or General-Purpose AI
New York’s RAISE Act was passed as A6453A and is currently reflecting expected chapter amendments in A9449.
AI Bills We’re Monitoring
2026 has begun with at least 19 new chatbot bills across the U.S. Notably, in California, two new bills and two ballot initiatives have merged. Of particular interest is SB 867, which aims to prohibit the manufacture, sale, exchange, and possession of any toy that includes a companion chatbot.
Additionally, Florida’s “Artificial Intelligence Bill of Rights” formalizes legislation proposed by Governor Ron DeSantis. SB 482 aims to protect minors by prohibiting them from creating chatbot accounts without a guardian’s consent and restricts the sale or disclosure of users’ personal information without deidentification.
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