Notes on the law of artificial intelligence — written by lawyers, for lawyers.
When we started this blog in May 2024, the EU AI Act had just cleared its final political hurdle, California's SB 1047 was a curiosity, and "AI agent" was a term you mostly heard from venture capitalists. Two years on, the legal terrain looks very different. Here is what has solidified, what has fragmented, and what we still do not know.
The Frontier Artificial Intelligence Safety and Innovation Act, signed last week, is the first federal statute to impose substantive obligations on developers of frontier-scale AI models. Compute thresholds, third-party evaluations, and mandatory pre-deployment notifications all make an appearance. We unpack what is actually new, what is borrowed, and where the inevitable preemption fights will land.
After two failed runs in prior Congresses, a slimmed-down DEEPFAKES Accountability Act passed the House in February and is now in Senate markup. The 2026 version drops the criminal provisions that doomed earlier iterations and instead leans on disclosure obligations and a private right of action. We compare the three versions side by side.
A handful of state courts have started reaching for fiduciary-duty language to describe what a deployer of a consumer-facing AI agent owes its user. The doctrine is incoherent so far, but the trajectory matters. We trace the cases, identify the unifying intuition, and explain why scope-of-engagement disclosures are about to become very important.
January 1 brought a stack of new California obligations into effect. The training-data disclosure rule (AB 2013), the AI content labeling regime (SB 942), and the automated decision-making rules under the CCPA regulations all started to bite at once. We walk through what changed, what remains unclear, and where compliance teams should focus first.
2025 was the year AI law stopped being primarily aspirational and became operational. Compliance deadlines actually arrived, regulators started bringing enforcement actions, and the first wave of agent-era litigation reached the merits. Here are the five trends that mattered most.