New York S 1169 (New York AI Act)

• Authority: New York
• Parent authority: State governments
• Jurisdiction: United States
• Collections: U.S. state and local documents
• Most recent activity: Proposed
• Most recent activity date: 2026-06-03

Risk subdomain coverage

Good coverage — Comprehensive governance measures or mitigations with clear procedures relating to the risk subdomain are explicitly described.

• Unfair discrimination and misrepresentation
• Unequal performance across groups
• Lack of capability or robustness
• Lack of transparency or interpretability

Minimal coverage — Brief mention but no specific mitigations, recommendations or governance measures relating to the risk subdomain are described.

• Compromise of privacy
• AI system security vulnerabilities
• Overreliance and unsafe use
• Loss of human agency and autonomy
• Increased inequality and decline in employment

All other risk subdomains had no coverage in this document.

Risk Coverage Summary

The document has strong coverage of approximately 6-7 subdomains, with primary focus on unfair discrimination (1.1), unequal performance (1.3), lack of robustness (7.3), and lack of transparency (7.4). The act centers on preventing algorithmic discrimination through comprehensive audit, reporting, and risk management requirements. Limited coverage of privacy concerns (2.1), human agency (5.2), and broader inequality issues (6.2).

Sector coverage

Good coverage — Comprehensive governance measures or mitigations with clear procedures relating to the sector are explicitly described.

• Finance & Insurance
• Real Estate, Rental & Leasing
• Professional & Technical Services
• Educational Services
• Health Care & Social Assistance

Minimal coverage — Brief mention but no specific mitigations, recommendations or governance measures relating to the sector are described.

• Information
• Management, Administrative & Support Services
• Public Administration (excl. National Security)

All other sectors had no coverage in this document.

Sectors Summary

The document governs AI use across multiple sectors through its definition of 'consequential decisions,' with strongest coverage in Employment, Education, Healthcare, Financial Services, and Housing. The act applies cross-sector to any AI system making decisions affecting employment, education, housing, family planning, healthcare, financial services, or legal services for New York residents.

Legislative Status

Hard Law

Legislative Status Summary

This is a proposed state statute with binding legal obligations, mandatory language throughout (shall, must, required), explicit civil penalties for violations, court enforcement mechanisms via the Attorney General, and formal reporting requirements to the Department of Financial Services.

Actors

Proposer

• Entity Types: AI_Governance_Actor
• Entities: New York State Legislature; New York State Senate and Assembly
• Summary: This is a legislative bill proposed by the New York State Legislature, as indicated by the enacting clause and bill designation S 1169.

Target

• Entity Types: AI_Developer, AI_Deployer
• Entities: Covered Developers; Covered Deployers; AI developers and deployers conducting business in New York or targeting New York residents
• Summary: The act explicitly targets developers who train AI systems and deployers who use AI systems for consequential decisions affecting New York residents. It defines and regulates both 'covered developers' and 'covered deployers' throughout.

Enforcer

• Entity Types: AI_Governance_Actor
• Entities: New York Attorney General; New York Supreme Court
• Summary: The Attorney General is explicitly designated as the primary enforcer with authority to bring enforcement actions, promulgate rules, and evaluate compliance. The Supreme Court has jurisdiction over enforcement actions.

Monitor

• Entity Types: AI_Governance_Actor
• Entities: New York Department of Financial Services; New York Attorney General; Independent third-party auditors
• Summary: The Department of Financial Services receives all audit reports and compliance filings from covered entities. The Attorney General monitors compliance and can evaluate risk management programs. Independent auditors conduct mandatory audits of high-risk AI systems.

AI Lifecycle Stages

Lifecycle stages covered by the documents, as defined in the OECD Framework for the Classification of AI Systems

• Plan and Design
• Collect and Process Data
• Build and Use Model
• Verify and Validate
• Deploy
• Operate and Monitor

AI Lifecycle Summary

The document comprehensively covers multiple AI lifecycle stages with particular emphasis on validation/audit, deployment, and ongoing monitoring. It establishes requirements spanning from initial planning through operational oversight, with detailed provisions for risk management throughout the lifecycle.

Technical Scope

Terms relating to technical scope that are mentioned or implicitly referenced in the document

• AI Systems

Technical Scope Summary

The document explicitly defines and focuses on 'AI systems' and 'high-risk AI systems' as its primary technical scope. It does not mention frontier AI, general purpose AI, foundation models, generative AI, predictive AI, compute thresholds, or open-weight models. The focus is on AI systems used for consequential decisions affecting individuals.