Direct comparison
SB 53 vs RAISE Act: Incident Reporting Compared
Compares California SB 53 and New York's RAISE Act on incident-reporting deadlines, whistleblower protections, penalties, and effective dates.
Written and maintained by CASRAI Editorial Board
Last updated
Ask CASRAI · free to try
Ask about SB 53 vs RAISE Act: Incident Reporting Compared
Ask your first 2 questions free below. Subscribers get 150 a day for $29 a month.
Ask CASRAI answers research-administration questions and cites the passages behind every claim. When our sources don't cover a question, it says so.
Answers draw on CASRAI's guides and dictionary plus the federal and funder documents we index: Federal Register, Grants.gov, Regulations.gov and UKRI.
Works on this site and inside Claude, Cursor and the AI tools you already use.
Everything CASRAI publishes — this page, the dictionary, the guides and the news — stays free to read, with no account and no card.
How do California SB 53, New York RAISE Act compare side by side?
The table below compares California SB 53, New York RAISE Act across 5 procurement-relevant dimensions, from what triggers coverage through effective dates.
Side-by-side comparison
| Dimension | California SB 53 | New York RAISE Act |
|---|---|---|
| What triggers coverage | Two tiers. Any "frontier developer" — trained, or has begun training, a foundation model using more than 10^26 integer or floating-point operations of compute — owes a baseline transparency report. The heavier duties (a public frontier AI framework, catastrophic-risk detail in transparency reports) apply only to "large frontier developers": frontier developers whose annual gross revenue, with affiliates, exceeded $500 million in the prior calendar year. | Coverage centers on "large frontier developers": entities that have trained a frontier model using more than 10^26 operations of compute and had annual gross revenue exceeding $500 million in the prior calendar year (the revenue figure was aligned to match SB 53's via an April 2026 amendment). Published summaries of the enacted text describe the RAISE Act's substantive duties — safety-protocol publication, incident reporting — as attaching at this large-developer threshold; they do not describe a separate, lighter baseline duty for frontier developers below it, unlike SB 53. |
| Incident-reporting deadline and recipient | 15 days from discovery, to the California Office of Emergency Services (Cal OES). If the incident poses an imminent risk of death or serious physical injury, the window shortens to 24 hours and the report goes to the appropriate law enforcement or public safety authority instead. | 72 hours from the developer learning of the incident, or learning facts sufficient to establish a reasonable belief one occurred, to the New York Attorney General and the state Division of Homeland Security and Emergency Services (DHSES). A separate oversight office housed in the Department of Financial Services administers compliance more broadly and publishes an annual report. Published summaries of the enacted text do not describe a shortened sub-window comparable to SB 53's 24-hour imminent-danger channel. |
| Whistleblower protection mechanism | Labor Code section 1107.1: covered employees and contractors cannot be barred or retaliated against for disclosing a catastrophic risk, or a violation of SB 53's transparency/safety-framework chapter, to the state Attorney General, a federal authority, a supervisor, or another employee with authority to investigate. Large frontier developers must also run an anonymous internal reporting channel with monthly status updates; a prevailing plaintiff can recover attorney's fees. | None in the enacted statute. An earlier Senate draft (S6953-A) included an employee-protection section, but it was removed before the bill Governor Hochul signed (S6953-B) became law — the RAISE Act as enacted has no whistleblower or anti-retaliation provision tied to frontier-AI-safety disclosures. |
| Penalties and enforcement | Enforced exclusively by the California Attorney General through civil actions; the statute creates no private right of action. Civil penalties run up to $1,000,000 per violation, scaled to severity, with no separate per-day accrual specified. | Enforced by the New York Attorney General through civil actions; no private right of action. Civil penalties run up to $1,000,000 for a first violation and up to $3,000,000 for subsequent violations — reduced from the $10 million / $30 million the legislature originally passed, via a chapter amendment negotiated before signing. Separately, the DFS oversight office can impose penalties of $1,000 per day, after notice and a hearing, for failing to file or correct a required disclosure. |
| Effective dates | Signed September 29, 2025. Core obligations — framework publication, transparency reports, incident reporting, whistleblower protections — took effect January 1, 2026. | Signed December 19, 2025. As passed by the legislature, the law would have taken effect 90 days after enactment; a chapter amendment delayed that to January 1, 2027. As of this writing (September 2026), the RAISE Act is not yet in force. |
Common questions
Common questions about California SB 53 vs New York RAISE Act
Could one company be subject to both SB 53 and the RAISE Act?
+
Yes. Both laws apply based on where a frontier developer trains models and does business, not where it is incorporated or headquartered. A large frontier developer operating in both California and New York can owe transparency-report and incident-reporting duties under both statutes at once, on different clocks and to different recipients.
Is the RAISE Act already in effect?
+
No, not as of September 2026. Governor Hochul signed the RAISE Act on December 19, 2025, but a chapter amendment pushed its effective date to January 1, 2027. SB 53, by contrast, has been in force since January 1, 2026.
Does the RAISE Act protect employees who report safety concerns?
+
No. An earlier Senate draft (S6953-A) included an employee-protection section, but it was removed before the enacted bill (S6953-B) was signed into law. SB 53's Labor Code section 1107.1 whistleblower provision has no RAISE Act counterpart.
Which law has the faster incident-reporting clock?
+
RAISE Act's flat 72-hour window is faster than SB 53's general 15-day window for critical safety incidents. SB 53 does have its own faster 24-hour channel, but that one applies only to a narrower case: an incident posing imminent risk of death or serious physical injury, reported to law enforcement or public safety rather than Cal OES.
Going deeper
