New York Gov. Kathy Hochul has appointed Marc Gilman to help oversee the state’s new AI regulatory regime as New York prepares to enforce safety requirements for large frontier model developers.
Gilman, a technology attorney at the New York State Department of Financial Services, will serve as deputy director for implementation of the Responsible AI Safety and Education Act, known as the RAISE Act.
His work will sit within the state’s new Office of Digital Innovation, Governance, Integrity and Trust, or DIGIT, housed at the Department of Financial Services.
Hochul also said New York intends to examine additional AI safety measures beyond requirements already written into state law. Those discussions include the possibility of emergency shutoff mechanisms for advanced models if state officials determine such systems are technically feasible and appropriate.
The proposal follows a similar move in California. Gov. Gavin Newsom issued a September 18 executive order directing state agencies and outside experts to develop recommendations around stronger oversight of frontier AI systems, including an emergency shutoff mechanism often described as an AI kill switch.
Technical details remain unresolved. An effective shutdown system would need to address how a frontier model operates across infrastructure, who receives authority to trigger the mechanism and whether a developer retains the ability to restart or replicate the system elsewhere.
New York’s RAISE Act puts the state among the most active US jurisdictions regulating large frontier AI developers. Hochul signed the legislation in December 2025, followed by negotiated amendments enacted in March 2026, with its main requirements scheduled to take effect January 1, 2027.
The law applies transparency and safety requirements to large developers rather than the broader market for smaller AI products.
Covered companies must publish safety and security protocols, maintain specified risk controls and report defined critical safety incidents to state authorities.
Large frontier developers will begin registering with New York in November 2026 ahead of full compliance in January. Once the rules take effect, developers must report critical safety incidents within 72 hours and provide required information to the DIGIT office.
The law also gives New York regulators authority to oversee compliance and pursue civil penalties for violations. DIGIT will operate inside the Department of Financial Services, which already regulates banks, insurers and other financial companies operating in the state.
New York proposed the DIGIT office earlier in 2026 as a central unit for digital safety and technology governance. The state’s fiscal 2027 budget included $21.2 mn for establishing the office within DFS.
Hochul has linked the state effort to the absence of a comparable federal framework for frontier AI safety. Speaking about federal policy, she criticized President Donald Trump’s administration and argued that states need to establish their own safeguards when national rules don’t cover the same risks.
Her comments place New York alongside California in developing state-level rules for companies producing advanced AI models. Both states require large developers to disclose information about safety practices and report serious incidents, though the statutes differ in structure and enforcement.
California expanded its framework again in September. Newsom signed measures establishing standards for independent AI safety assessments and a state registry for auditors, then issued an executive order asking experts to study further measures for frontier models.
That order specifically calls for work on an emergency shutoff system whose effectiveness would receive independent verification. California officials are also considering requirements for outside verification groups to conduct recurring audits of frontier AI developers.
New York hasn’t adopted a kill-switch requirement. Hochul described the idea as one of the safeguards the state plans to examine as regulators build out the RAISE Act framework.
Gilman brings experience from both regulatory work and the technology sector. Before joining DFS, he served as general counsel and vice president of compliance at software company Theta Lake, and his background includes technology law and regulatory compliance.
Hochul said that experience should help the state deal with legal arguments from large technology companies as enforcement begins.
Gilman’s immediate responsibility centers on implementing the RAISE Act and building the regulatory process that frontier developers will face beginning in 2027.
For OpenAI, Anthropic and other large AI developers operating within the law’s scope, the first operational deadline arrives with registration in November. Formal compliance starts January 1, when reporting, transparency and safety obligations become enforceable under New York law.
