Lines of Thought

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.

  1. Rule · Partly in forceEU
    EU 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?

  2. Rule changeFrontierEU
    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.

  3. Rule changeFrontierUS-CA
    California enacts SB 53, first US state law on frontier AI transparency

    California sets the US template: frameworks, incident reports, whistleblowers.

  4. Rule · In forceUS
    State 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?

  5. Rule changeFrontierUS-NY
    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.

  6. Rule · In forceINTL
    International AI Safety Report

    The shared scientific baseline governments cite for these rules.

  7. Rule changeFrontierEU
    EU AI Office gains powers to enforce AI Act rules on general-purpose models

    EU gains fining and model-access powers over frontier providers.

  8. Rule · In forceUS
    EO 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

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