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ARTICLE · 30 JANUARY 2026

AI Legal Watch: January 2026

Baker Botts L.L.P.
Baker Botts L.L.P.
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Baker Botts L.L.P.

Baker Botts L.L.P.

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Multiple significant state AI laws became effective January 1, 2026.

United StatesTechnology
Ben Bafumi
Ben Bafumi
Bradley Bennett
Bradley Bennett
Joseph Cahill
Joseph Cahill
Sarah J. Dodson
Sarah J. Dodson
Parker Hancock
Parker Hancock
Richard B. Harper
Richard B. Harper
Cailyn Reilly Knapp
Cailyn Reilly Knapp
Enrico Picozza
Enrico Picozza
Coleman Strine
Coleman Strine
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2026 United States AI Compliance: State Laws Take Effect Amid Federal Uncertainty
Joe Cahill
Multiple significant state AI laws became effective January 1, 2026. California's Transparency in Frontier AI Act (SB 53), signed September 29, 2025, requires developers of large AI models trained using greater than 10²⁶ FLOPS to publish risk frameworks, report critical safety incidents within 15 days, and implement whistleblower protections, with penalties up to $1 million per violation. Texas's Responsible AI Governance Act (HB 149), signed June 22, 2025, prohibits AI systems designed for "restricted purposes," including encouragement of self-harm, unlawful discrimination, and CSAM generation, with penalties ranging from $10,000–$12,000 for curable violations to $80,000–$200,000 for uncurable violations; no private right of action exists. Illinois's amendment to the Human Rights Act (HB 3773), signed August 9, 2024, makes it a civil rights violation to use AI for

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