New York AI Governance
New York regulates AI at both the state and city level, with no single unifying statute tying the pieces together. The RAISE Act governs frontier model developers, NYC’s Local Law 144 governs employment AI within city limits, a 2025 companion chatbot law protects consumers interacting with AI companions, and a first-of-its-kind algorithmic pricing law requires disclosure when AI sets a price using personal data. Insurers face a separate layer of guidance from the Department of Financial Services.
The New York Attorney General enforces the RAISE Act, with civil penalties up to $1 million for a first violation and $3 million for subsequent violations (reduced from an earlier $10 million/$30 million proposal), plus a separate $1,000-per-day penalty from DFS for failure to file a disclosure statement. There is no private right of action.
The NYC Department of Consumer and Worker Protection enforces the law, with civil penalties of $500 to $1,500 per day of violation, each day counted separately. A December 2025 New York State Comptroller audit found weak DCWP oversight to date, and DCWP has since launched targeted investigations of hundreds of employers in 2026, so enforcement activity is actively increasing.
The New York Attorney General enforces the law exclusively, with civil penalties up to $15,000 per day per violation, with proceeds funding state suicide-prevention programs. There is no private right of action and no annual reporting or public-posting obligation.
The New York Attorney General enforces the law, with penalties up to $1,000 per occurrence.
DFS enforces through its examination authority rather than a per-violation penalty statute. It’s supervisory guidance rather than a statute, but DFS enforces it through its examination authority over every NY-authorized insurer, HMO, and fraternal benefit society, making practical compliance effectively mandatory for regulated entities.
How Trustible Supports New York Compliance
Your First 90 Days
Day 30: Separate State, City, and Sector Obligations
Classify AI systems by which New York regime applies: RAISE Act frontier-model dependencies, NYC Local Law 144 employment tools, AI companion products, algorithmic pricing tools, or DFS-regulated insurance AI.
Day 60: Complete Bias Audits and Disparate-Effect Assessments
Run or refresh the annual independent bias audit required for any AEDT used to evaluate NYC-resident candidates, and complete DFS’s three-step disparate-effect assessment for any underwriting or pricing AI.
Day 90: Publish Required Disclosures and Confirm Vendor Documentation
Post bias audit summaries publicly as Local Law 144 requires, confirm AI companion disclosure cadence and self-harm protocols are live, and verify foundation model vendors can produce RAISE Act safety and transparency documentation ahead of the January 2027 effective date.
New York AI FAQs
January 1, 2027. The original bill was signed December 19, 2025, but a chapter amendment finalized in March 2026 changed key thresholds and delayed the effective date.
Yes, if the employer uses an Automated Employment Decision Tool to evaluate a candidate or employee who resides in New York City, regardless of where the employer itself is located.
No. Unlike California’s comparable law, New York’s AI companion disclosure and self-harm safety protocol requirements apply to all users regardless of age.
A conspicuous disclosure, both online and in-store, stating that the price was set by an algorithm using the consumer’s personal data, unless the business falls under an exemption such as insurance or federally regulated financial services.
It’s supervisory guidance rather than a statute, but DFS enforces it through its examination authority over every NY-authorized insurer, HMO, and fraternal benefit society, making practical compliance effectively mandatory for regulated entities.