NY RAISE Act revision: 11 key updates, from 10^25 threshold to whistleblower protections
StephenLCasper · x · 2026-10-31
Researcher Stephen Casper reviews the revised NY RAISE Act, calling the updates significant and long-awaited, and lists his 11 favorites:
- Expanded "critical safety incident" definition, covering some near misses
- Frontier compute threshold lowered to 10^25 operations
- New state office issuing regulations and orders
- Most specific legislative language yet on third-party evaluator access
- More transparency/reporting on internal deployments, including R&D
- Mandatory designated compliance official at large frontier developers
- Third-party assessments now mandatory
- Evaluators can dispute redactions; state licenses evaluators
- State emergency powers to restrict training/inference; explicit NY AG injunction authority
- New whistleblower protections
- (Later in thread) a proposed Sarbanes-Oxley-style 5-year document preservation requirement
He also flags needed improvements: more specificity on counting compute, and a process for adjudicating evaluator-access disputes.
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