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Jan 29, 2026GuidanceUS federal
FDA reissues clinical decision support software guidance with a minor correction
The January 29, 2026 guidance supersedes the version issued January 6, 2026. FDA describes the change as a minor correction deleting a reference to time-critical decision-making on pages 13 and 14 for alignment with the January 6 update. The guidance says FDA does not consider software functions intended for a critical, time-sensitive task or decision to meet Criterion 4.
Source: U.S. Food and Drug Administration · Guide: AI in health care
Applies to: Hospitals and health systems
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Jan 15, 2026LawUS federal
25 percent Section 232 tariff on certain advanced AI chips takes effect
Proclamation 11002 imposes a 25 percent duty on covered logic chips, and articles containing them, under HTSUS 8471.50, 8471.80, and 8473.30 that meet set performance parameters, entered on or after January 15, 2026. Excluded: imports for US data centers, repairs or replacements in the United States, research and development in the United States, use by startups, non-data center consumer and civil industrial applications in the United States, US public sector applications, and other uses the Secretary of Commerce determines strengthen the US technology supply chain. No drawback is allowed, and covered goods entering a foreign trade zone must take privileged foreign status.
Source: Proclamation 11002, 91 FR 2443 · Guide: AI compliance, layer by layer
Applies to: Importers and exporters
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Jan 15, 2026Final ruleUS federal
BIS moves H200-class chip exports to China from presumption of denial to case-by-case review
For exports from the United States to end users in China or Macau of chips with TPP below 21,000 and DRAM bandwidth below 6,500 GB/s, such as the NVIDIA H200 or AMD MI325X, BIS reviews applications case by case if, among other conditions, the chip is commercially available in the United States and the applicant certifies sufficient US supply, no diversion of foundry capacity needed for US end users, China and Macau shipments of no more than 50 percent of US end-use shipments, rigorous KYC by the ultimate consignee, and review of every shipment by a qualified third-party testing lab in the United States. Exports to D:5- or Macau-headquartered entities elsewhere remain under a presumption of denial.
Source: Revision to License Review Policy for Advanced Computing Commodities, 91 FR 1684 · Guide: AI compliance, layer by layer
Applies to: Importers and exporters
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Jan 8, 2026ProposalUS federal
CAISI requests information on security considerations for AI agents
The Federal Register notice (Docket NIST-2025-0035) states that AI agent systems are capable of planning and taking autonomous actions that impact real-world systems or environments and may be susceptible to hijacking, backdoor attacks, and other exploits. Comments were due March 9, 2026. A request for information imposes no duties.
Source: Federal Register, 91 FR, January 8, 2026 (2026-00206) · Guide: Agentic AI governance
Applies to: All industries
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Jan 1, 2026LawCalifornia
California AB 325 on common pricing algorithms takes effect
Makes it unlawful under the Cartwright Act to use or distribute a common pricing algorithm as part of a contract, combination, or conspiracy in restraint of trade, or while coercing another person to adopt its recommended price or commercial term. Reaches portfolio companies using shared pricing tools.
Source: AB-325 Cartwright Act: violations, California Legislative Information · Guide: AI pricing and antitrust
Applies to: Private equity and asset managers
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Jan 1, 2026DeadlineUS federal
CMS WISeR Model begins AI-assisted prior authorization review in six states
Traditional Medicare providers in New Jersey, Ohio, Oklahoma, Texas, Arizona, and Washington may request prior authorization for listed services or face pre-payment medical review. CMS states that all recommendations for non-payment are determined by appropriately licensed clinicians; the model runs through December 31, 2031.
Source: Centers for Medicare & Medicaid Services · Guide: AI in health care
Applies to: Hospitals and health systems
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Jan 1, 2026DeadlineTexas
Texas HB 149 health care AI disclosure takes effect
Providers must disclose AI use in a service or treatment to the patient or personal representative by the date it is first provided, or, in an emergency, as soon as reasonably possible (Sec. 552.051(f)).
Source: Texas Legislature · Guide: US state AI laws
Applies to: Hospitals and health systems
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Jan 1, 2026LawNebraska
Nebraska LB 77 bars AI-based algorithms as the sole basis of medical necessity denials
An AI-based algorithm may not be the sole basis of a utilization review agent's decision to deny, delay, or modify services based in whole or in part on medical necessity. Agents must disclose AI use to the department, network providers, enrollees, and on their public website.
Source: LB 77 slip law, Nebraska Legislature · Guide: AI in health care
Applies to: Insurers · Hospitals and health systems
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Jan 1, 2026LawIllinois
Illinois HB 3773 takes effect: AI use with discriminatory effect barred in employment
The amended Human Rights Act makes it a civil rights violation for an employer to use AI in recruitment, hiring, promotion, renewal of employment, selection for training or apprenticeship, discharge, discipline, tenure, or the terms, privileges, or conditions of employment in a way that has the effect of discriminating, bars zip codes as a proxy, and makes failure to give notice a violation.
Source: Public Act 103-0804, Illinois General Assembly · Guide: AI in hiring and HR
Applies to: Employers and HR
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Jan 1, 2026LawCalifornia
California SB 53, the Transparency in Frontier Artificial Intelligence Act, takes effect
SB 53 (Chapter 138, Statutes of 2025) applies to frontier developers, meaning persons who trained a foundation model using more than 10^26 integer or floating-point operations, with added duties for large frontier developers with annual gross revenues above $500 million, with affiliates, in the preceding calendar year. It requires a transparency report before or at deployment of a new or substantially modified frontier model, a published frontier AI framework from large frontier developers, reports of critical safety incidents to the Office of Emergency Services within 15 days of discovery or within 24 hours to an appropriate authority where there is an imminent risk of death or serious physical injury, and whistleblower protections (Labor Code 1107 to 1107.2). Civil penalties of up to $1,000,000 per violation, which apply to large frontier developers, may be recovered only by the Attorney General; covered employees may sue under the whistleblower provisions.
Source: SB 53, Chapter 138, Statutes of 2025, California Legislative Information · Guide: California AI laws
Applies to: All industries
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Jan 1, 2026LawCalifornia
California AB 2013 training data disclosure duty applies
AB 2013 (Chapter 817, Statutes of 2024) required a developer of a generative AI system or service, or a substantial modification, released on or after January 1, 2022 and made available to Californians to post on its website, on or before January 1, 2026 and before each later release, a high-level summary of the datasets used in development, with the items the statute lists. xAI's challenge to the law was pending in the Ninth Circuit as of October 2026.
Source: AB 2013, Chapter 817, Statutes of 2024, California Legislative Information · Guide: California AI laws
Applies to: All industries
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Jan 1, 2026LawCalifornia
California SB 243 companion chatbot law takes effect
SB 243 (Chapter 677, Statutes of 2025) requires an operator that makes a companion chatbot platform available to users in California to issue a clear and conspicuous notification that the chatbot is artificially generated and not human where a reasonable person would be misled to believe they are interacting with a human, to maintain and publish a protocol for preventing suicidal ideation, suicide, or self-harm content that refers users to crisis services, and to disclose that companion chatbots may not be suitable for some minors. Annual reporting to the Office of Suicide Prevention begins July 1, 2027. A person injured by a violation may sue for injunctive relief, the greater of actual damages or $1,000 per violation, and reasonable attorney's fees and costs. Exclusions include bots used only for customer service or a business's operational purposes, certain video game bots, and certain voice assistant devices. SB 1119 (Chapter 190, Statutes of 2026) deletes the separate duties for users the operator knows are minors, effective January 1, 2027.
Source: SB 243, Chapter 677, Statutes of 2025, California Legislative Information · Guide: California AI laws
Applies to: All industries
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Jan 1, 2026LawCalifornia
California AB 489 bars AI systems from implying a health care license
AB 489 (Chapter 615, Statutes of 2025) adds Business and Professions Code 4999.8 and 4999.9. The existing prohibitions on using terms, letters, or phrases that indicate or imply possession of a health care license or certificate are enforceable against a person or entity that develops or deploys an AI or generative AI system that uses them in its advertising or functionality. Each use is a separate violation, subject to the jurisdiction of the appropriate health care professional licensing board or enforcement agency, which may seek an injunction under Section 125.5.
Source: AB 489, Chapter 615, Statutes of 2025, California Legislative Information · Guide: California AI laws
Applies to: Hospitals and health systems
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Jan 1, 2026LawTexas
Texas HB 149 (TRAIGA) prohibitions and Attorney General enforcement take effect
Business and Commerce Code Chapters 551 to 554 take effect: intent-based prohibitions on manipulation, constitutional infringement, unlawful discrimination, and certain sexual content for any person, social scoring and biometric identification limits for governmental entities, an AI interaction disclosure duty for governmental agencies, Attorney General enforcement after written notice and a 60-day cure with penalties of $10,000 to $200,000 per uncured violation and $2,000 to $40,000 for each day a violation continues, a regulatory sandbox, and the Texas Artificial Intelligence Council.
Source: H.B. No. 149 (enrolled), Texas Legislature · Guide: Texas AI law (HB 149)
Applies to: All industries