Compliance

Large frontier developer

Frontier developer with >$500 million annual revenue.

How the laws define this

Regulatory frameworks consistently identify large frontier developers as entities responsible for creating, training, or deploying frontier AI models that meet major capacity thresholds, making them the primary subjects of mandatory safety and transparency rules. The main divergence lies in how these regulatory thresholds are defined across different instruments. California SB 53 — Transparency in Frontier Artificial Intelligence Act (TFAIA) specifies combined annual gross revenues exceeding $500 million in the preceding calendar year. The Great American AI Act similarly highlights a revenue threshold exceeding $500 million, whereas the Artificial Intelligence Safety Measures Act combines revenue and computational resources with the capacity to pose severe or catastrophic risks to public safety. Meanwhile, the Transparency in Frontier Artificial Intelligence Act focuses on powerful, general-purpose models defined by the California Department of Technology, imposing mandatory safety frameworks, incident reporting, and internal governance.

Synthesised from the 6 statutory definitions below. Each one is quoted in full, with its source.

How jurisdictions differ

What is distinctive in each definition, binding law in force first. Showing 5 of the 6 instruments that define this term; all are listed under Definitions below.

Jurisdiction	Instrument	Status	What is distinctive
California, United States	California SB 53 — Transparency in Frontier Artificial Intelligence Act (TFAIA)	In Force	Defines the term through a specific revenue threshold of combined annual gross revenues exceeding $500 million with affiliates in the preceding calendar year.
New York, United States	An Act to amend the general business law, in relation to transparency and safety requirements for developers of artificial intelligence frontier models	In Force	Provides no specific criteria like revenue or compute thresholds, merely identifying entities responsible for frontier models as subject to transparency and safety requirements.
Illinois, United States	Artificial Intelligence Safety Measures Act	Adopted	Characterizes qualifying entities by substantial computational resources, significant revenue thresholds, and capacity to create AI posing severe or catastrophic risks.
United States	The Great American AI Act	Proposed	Designates the term based on revenue exceeding $500 million as an indicator of substantial influence and capacity in the AI ecosystem.
California, United States	Transparency in Frontier Artificial Intelligence Act	In Force	Defines through responsibility for creating and managing powerful general-purpose models as designated by the California Department of Technology.

What it triggers

In California under SB 53, large frontier developers must publish safety frameworks.source
In California under the Transparency in Frontier Artificial Intelligence Act, they are subject to mandatory safety frameworks, incident reporting, and internal governance requirements.
In New York under An Act to amend the general business law, in relation to transparency and safety requirements for developers of artificial intelligence frontier models, they must comply with transparency and safety requirements.
Under the Artificial Intelligence Safety Measures Act in Illinois, they must undergo independent third-party audits for frontier AI models.source

Definitions (6)

A frontier developer whose combined annual gross revenues with its affiliates exceeded $500 million in the preceding calendar year; entities meeting this threshold are subject to the Act's primary compliance requirements.

California SB 53 — Transparency in Frontier Artificial Intelligence Act (TFAIA)Definition 1 of 6

An entity defined by the Act as having trained at least one frontier model, typically characterized by significant computational resources expended or substantial revenue generated. These developers are subject to the Act's transparency and safety requirements.

An act to amend the general business law, in relation to transparency and safety requirements for developers of artificial intelligence frontier models; to amend a chapter of the laws of 2025 amending the general business law relating to the training and use of artificial intelligence frontier models, as proposed in legislative bills numbers S. 6953-B and A. 6453-B, in relation to the effectiveness thereof; and to repeal certain provisions of the general business law, relating theretoDefinition 2 of 6

An entity that develops or deploys frontier models, characterized by substantial computational resources, significant revenue thresholds, and the capacity to create AI systems that could pose severe or catastrophic risks to public safety.

Artificial Intelligence Safety Measures ActDefinition 3 of 6

Designated based on specific thresholds, typically involving revenue generation exceeding a certain amount (e.g., $500 million), indicating their substantial influence and capacity within the AI ecosystem.

The Great American AI ActDefinition 4 of 6

A large frontier developer is an entity responsible for creating and managing the most powerful and general-purpose AI models, as defined by the California Department of Technology. These developers are subject to mandatory safety frameworks, incident reporting, and internal governance requirements under the Act.

Transparency in Frontier Artificial Intelligence ActDefinition 5 of 6

Entities responsible for the development of artificial intelligence frontier models that meet specific thresholds. These developers are the primary subjects of the Act's regulatory mandates, including transparency and safety requirements.

An Act to amend the general business law, in relation to transparency and safety requirements for developers of artificial intelligence frontier modelsDefinition 6 of 6

Not to be confused with

AI developer/provider

AI developer/provider covers any entity that develops, deploys, or offers AI products or services, while large frontier developer applies only to those handling frontier models under specific regulatory thresholds.

Developer

Developer refers broadly to any entity creating or substantially modifying AI systems, whereas large frontier developer is limited to those meeting revenue or capability thresholds for frontier models.

Questions and answers

What revenue threshold defines a large frontier developer in California SB 53?

It is an entity whose combined annual gross revenues with affiliates exceeded $500 million in the preceding calendar year. Entities meeting this are subject to the Act's primary compliance requirements.

What obligations apply to large frontier developers under California's Transparency in Frontier Artificial Intelligence Act?

They must adhere to mandatory safety frameworks, incident reporting, and internal governance requirements. The Act targets developers of the most powerful AI models.

How does the Illinois Artificial Intelligence Safety Measures Act define large frontier developers?

It covers entities developing or deploying frontier models with substantial computational resources, significant revenue thresholds, and capacity for severe risks. They require independent third-party audits.