What Would It Take to Enforce the RAISE Act? Institutional Capacity and Frontier AI Oversight in New York

Artificial intelligence (AI) presents growing governance challenges that have outpaced federal statutory regulation. In response, states have increasingly stepped in to develop oversight frameworks shaped by both regulatory gaps and state-level policy priorities. New York’s Responsible AI Safety and Education (RAISE) Act, as passed by the State Legislature, would establish a detailed state approach to frontier AI oversight and would grant the Attorney General broad enforcement authority. While the Act’s statutory design is robust, this paper finds that enforcement capacity would likely constrain its effectiveness. Existing staffing levels, technical expertise, and dedicated funding are not yet sufficient to support implementation at the scale envisioned. Assessing these constraints across the Department of Law and relevant partner agencies, and situating New York’s approach alongside California’s enacted Transparency in Frontier AI Act, the paper concludes that the effectiveness of any enacted RAISE framework would depend on institutional capacity, implementation choices, and targeted investment in personnel, technical infrastructure, and interagency coordination, particularly in the continued absence of comprehensive federal AI legislation.