Transparency, not licensing
What legal duties do frontier AI developers actually face in 2026, and where?
Instead of licensing, the EU, California and New York converged on published safety frameworks, incident reporting and regulator access to models. Federal US policy pushes back on state laws while relying on voluntary testing.
- Rule · Partly in forceEUEU AI Act
The first binding law with specific duties for general-purpose and systemic-risk models.
Also on Project Meridian and the race to govern military AI, Who decides if a medical AI is safe?
- EU publishes General-Purpose AI Code of Practice ahead of AI Act model duties
The code most major labs signed to show compliance; xAI only partly.
- California enacts SB 53, first US state law on frontier AI transparency
California sets the US template: frameworks, incident reports, whistleblowers.
- Rule · In forceUSState AI law preemption EO
Federal order targeting state AI laws raises pre-emption risk for SB 53-style rules.
Also on Can an algorithm deny your care?
- New York finalises RAISE Act, aligning frontier AI law closely with California
New York converges on California's model but with 72-hour reporting and a DFS regulator.
- Rule · In forceINTLInternational AI Safety Report
The shared scientific baseline governments cite for these rules.
- EU AI Office gains powers to enforce AI Act rules on general-purpose models
EU gains fining and model-access powers over frontier providers.
- Rule · In forceUSEO 14409 (covered frontier models)
US prefers voluntary pre-release testing and explicitly rules out licensing.
Also on The Pentagon, the labs and the limits on use, Project Meridian and the race to govern military AI, When models learned to hack
Where this line could go next
Connected developments not on this line
- DevelopmentEU Digital Omnibus on AI enters force, delaying high-risk AI Act duties to 2027-2827 Jul 2026 · Rule change · EU
- DevelopmentEU finalises code of practice on marking and labelling AI-generated content10 Jun 2026 · Policy · EU
- DevelopmentAnthropic study finds 16 leading models resort to blackmail in agent stress tests20 Jun 2025 · Research · US
- DevelopmentOpenAI starts watermarking ChatGPT and Codex text in the EU to meet AI Act rules5 Oct 2026 · Launch · EU
- DevelopmentTrump executive order targets state AI laws with litigation and funding pressure11 Dec 2025 · Policy · US
- DevelopmentSouth Korea's AI Basic Act takes effect, with a one-year pause on fines22 Jan 2026 · Rule change · KR