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The RAISE Act Focuses AI’s Impact On Consumers, Workers, and Vulnerable Populations
By David Carlucci
New York has taken another decisive step into the fast-moving world of artificial intelligence policy. On December 19th Governor Kathy Hochul signed the RAISE (Responsible AI Safety and Education) Act, a measure aimed at strengthening transparency, accountability, and consumer protections as AI systems become more deeply embedded in everyday business and civic life.
The timing is no accident. The law arrives amid growing uncertainty for states seeking to regulate AI, as a new federal executive order signals potential limits on state-level authority. Under that order, states that do not align with emerging federal frameworks could risk losing congressionally approved broadband funding. Despite this pressure, New York lawmakers have chosen to keep moving forward.
So how does this actually work, and what does it mean for businesses?
What the RAISE Act Does
At its core, the RAISE Act is about guardrails, not roadblocks. The law focuses on how AI systems are deployed, particularly when they may impact consumers, workers, or vulnerable populations. Rather than banning technologies, the Act emphasizes:
- Disclosure and transparency around how certain AI tools are used;
- Risk mitigation requirements for high-impact systems; and,
- Accountability standards for developers and deployers operating in New York.
For businesses, this means a shift from “build fast and figure it out later” to build responsibly and document your process.
Why the Federal Backdrop Matters
The new federal executive order complicates the picture. By tying broadband funding to compliance with federal AI priorities, Washington is signaling a desire for national uniformity. That creates a tension: states want to respond to local concerns, while the federal government wants to avoid a patchwork of rules.
New York’s approach suggests state leaders believe they can do both. The RAISE Act is designed to complement, not directly conflict with, federal goals such as innovation, competitiveness, and infrastructure expansion. Still, the risk is real. If federal agencies determine that certain state provisions overstep, funding disputes could follow.
What This Means for New York Businesses
For companies operating in or expanding into New York, the RAISE Act is less about fear and more about preparation. As such:
- AI governance is now a business issue, not just a technical one;
- Compliance planning should start early, especially for firms using AI in hiring, healthcare, finance, or customer interaction; and,
- Documentation, internal audits, and vendor due diligence will matter more than ever.
In practical terms, businesses that already invest in compliance, ethics reviews, and data governance are likely ahead of the curve.
The Bigger Picture
New York has a long history of acting first in areas like consumer protection, finance, and data privacy. The RAISE Act fits that pattern. Even as federal policy continues to evolve, state lawmakers are signaling that waiting on Washington is not a strategy.
The message is clear: AI innovation is welcome, but responsibility is non-negotiable.
As implementation timelines and regulatory guidance emerge, companies should stay engaged and proactive. Those that treat this moment as an opportunity to lead, rather than a burden to manage, may find themselves better positioned not just in New York, but nationally.
Carlucci Consulting is monitoring implementation timelines, forthcoming guidance, and potential federal-state interactions tied to the RAISE Act and related executive actions.
