AI Law Center: January 2026 Updates

In this month's update:

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AI Regulatory Landscape: Three Things to Know

1. What does New York's new AI law require from frontier model developers?

On December 19, New York enacted the RAISE Act, establishing AI framework requirements for large AI developers. The law mandates frontier AI frameworks and 72-hour incident reporting, with penalties in the millions for repeat violations. Read the Governor’s announcement.

2. How are state Attorneys General responding to potential federal preemption of AI laws?

A bipartisan coalition of 24 state AGs submitted comments opposing FCC efforts that could preempt state AI regulations, citing Tenth Amendment concerns and states' role as first responders to consumer complaints. Separately, the Attorney General Alliance’s new AI Task Force held its inaugural meeting. Read our State AG Update.

3. What do startups need to know as EU AI Act obligations take effect?

The EU AI Act's provisions include AI literacy obligations for AI providers, users, importers and distributors. Watch our video.

New U.S. State AI Laws by AI Scope

Below are the state AI laws that have been newly enacted or substantially updated:

AI in Employment

• New Jersey - Rules Pertaining to Disparate Impact Discrimination (N.J.A.C. 13:16)

AI in Government

• New York - The LOADinG Act: Legislative Oversight of Automated Decision-Making in Government Act (S 7543B). Recently amended and expanded by S7599C.

AI in Real Estate

• Wisconsin - Advertising Enhanced by Technology Law (Wis. Stat. § 452.136(1m).

Frontier or General-Purpose AI

• New York - The Responsible AI Safety and Education (RAISE) Act. Passed by the Legislature as A6453A. Currently shown reflecting chapter amendments widely expected to be passed in A9449.

See all enacted state laws >

AI Bills We’re Keeping an Eye On

New Chatbot Bill in California Aims to Prohibit Chatbot Toys

2026 kicked off with at least 19 new chatbot bills across the U.S. In California, two new bills and two ballot initiatives were merged. Of note, SB 867 would prohibit the manufacture, sale, exchange and possession with intent to sell any toy that includes a companion chatbot.

Florida’s “Artificial Intelligence Bill of Rights”

This bill formalizes legislation proposed by Republican Florida Governor Ron DeSantis last month. SB 482 would provide protections such as prohibiting minors from creating chatbot accounts without a guardian’s consent and prohibiting the sale or disclosure of users’ personal information without deidentification.

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