Key point: New York becomes the second state — after California — to enact an AI frontier model law, while the governor’s veto of the New York Health Information Privacy Act will be a welcome result for organizations that criticized the bill as unworkable.

In the last two weeks, New York Governor Kathy Hochul took action on numerous bills the New York legislature passed before it closed in June. Among those actions, Hochul signed four AI-related bills — including a bill regulating AI frontier models — and vetoed a controversial health data privacy bill. We discuss each of those bills in the article below.

In addition to these bills, earlier this year, New York lawmakers enacted three other AI-related laws — the Algorithmic Pricing Disclosure Act, a companion chatbot law, and a law regulating the use of algorithmic pricing by landlords.

Responsible AI Safety and Education (RAISE) Act (S6953B)

The governor signed the RAISE Act after negotiating chapter amendments with the legislature. The RAISE Act passed the legislature in June but was not delivered to the governor until December 9. The bill focuses on regulating AI frontier models. The chapter amendments align the bill with California’s Transparency in Frontier AI Act (SB 53), which Governor Gavin Newsom signed into law in September. See our summary of the California law here. According to various reports, the chapter amendments will align the New York law with California’s law, but New York’s law will go beyond the California law in some ways.

Enactment of the RAISE Act comes only days after President Trump signed an executive order seeking to preempt existing state AI laws, stop states from enacting new ones, and charging administration officials with developing a federal AI framework. In the governor’s press release, she referenced federal inaction on AI regulation as a justification for the New York law, stating: “This law builds on California’s recently adopted framework, creating a unified benchmark among the country’s leading tech states as the federal government lags behind, failing to implement common-sense regulations that protect the public.”

Disclosure of Synthetic Performers (S8420)

Subject to numerous exemptions, the bill requires advertisements to conspicuously disclose the use of a synthetic performer. The bill defines “synthetic performer” as “a digitally created asset created, reproduced, or modified by computer, using generative artificial intelligence or a software algorithm, that is intended to create the impression that the asset is engaging in an audiovisual and/or visual performance of a human performer who is not recognizable as any identifiable natural performer.”

Use of Digital Replicas (S8391)

The bill amends New York’s existing right of publicity law to prohibit the use of a digital replica of a deceased personality’s voice or likeness in an expressive audiovisual work without prior consent.

LOADinG Act Amendment (S7599C)

The bill amends the Legislative Oversight of Automated Decision-making in Government (LOADinG) Act. The legislature originally passed the LOADinG Act in 2024, but the bill was significantly narrowed through heavy chapter amendments before being signed by Hochul. This year’s amendment builds on the existing law by requiring, among other things, that government agencies disclose the use of automated decision-making tools and conduct impact assessments on those tools. It does not appear that the bill received chapter amendments before the governor signed it.

New York Health Information Privacy Act (S929)

Finally, the governor vetoed the controversial New York Health Information Privacy Act. The bill sought to regulate the processing of consumer health information in the state. However, the bill drew criticism from tech and other industry advocates who criticized it as unworkable.