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ARTICLE · 11 FEBRUARY 2026

How GCs Can Get Ahead Of California's Transparency In Frontier Artificial Intelligence Act

Boies Schiller Flexner LLP
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AI is transforming business operations by boosting productivity and innovation, but its "black box" nature makes risk assessment challenging.

United StatesTechnology
Corey P. Gray
Corey P. Gray
Rachel Noveroske
Rachel Noveroske

AI is transforming business operations by boosting productivity and innovation, but its "black box" nature makes risk assessment challenging. California's Transparency in Frontier Artificial Intelligence Act addresses this by requiring certain AI developers to meet new transparency and reporting rules. The act also offers whistleblower protections, introduces civil penalties, and urges general counsel to quickly adapt for compliance.

Transparency reports and incident reporting
Starting January 1, 2026, AI developers training models with over 10^26 operations (AI models requiring astronomically large amounts of computation) must post transparency reports online, detailing their release dates, intended uses, and restrictions. Those with annual revenues over $500 million ("large frontier developers") (LFDs) must also publish a ten-category frontier AI framework, update it yearly, and report major changes within 30 days to inform consumers about catastrophic risk

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