Comment by Scott Singer

Fellow and co-director of the China AI Initiative at the Carnegie Endowment for International Peace; researcher on advanced AI governance.
SB 53 begins to close this gap by requiring large frontier developers to describe their approach to assessing internal use risks and to transmit confidential summaries of “any assessment of catastrophic risk resulting from internal use of [their] frontier models” to OES, by default every three months. The RAISE Act and SB 315 followed suit, adopting nearly identical internal-use provisions and requiring the same quarterly risk assessment summaries and incident flagging.
Unverified (2026)
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