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ARTICLE · 13 OCTOBER 2025

California Governor Signs Transparency In Frontier Artificial Intelligence Act

Davis Polk & Wardwell
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The Transparency in Frontier Artificial Intelligence Act is the first U.S. law focused on developers of frontier AI models and will go into effect on January 1, 2026.

United StatesTechnology
Matthew J. Bacal
Matthew J. Bacal
David I. Feinstein
David I. Feinstein
James W. Haldin
James W. Haldin
David Lisson
David Lisson
Howard Shelanski
Howard Shelanski

The Transparency in Frontier Artificial Intelligence Act is the first U.S. law focused on developers of frontier AI models and will go into effect on January 1, 2026. 

Background

On September 29, California Governor Gavin Newsom signed into law the Transparency in Frontier Artificial Intelligence Act ("TFAIA"), which will go into effect on January 1, 2026. Among other things, TFAIA requires "frontier developers"—in effect, developers of general-purpose AI models that were trained using high levels of computational power—to publish a framework describing how they incorporate best practices and relevant benchmarks, identify and mitigate risks, respond to critical safety incidents and institute internal governance practices. TFAIA also requires frontier developers to disclose the results of "catastrophic risk" assessments before deploying new or substantially modified frontier models, and to notify California's Office of Emergency Services of any "critical safety

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