Transparency in Frontier Artificial Intelligence Act (TFAIA): Compliance Checklist

Compliance checklist

Run through these items to scope your obligations under Transparency in Frontier Artificial Intelligence Act (TFAIA). Not legal advice; verify with counsel before acting.

1. Confirm scope: does the law apply to your operations? See Who Must Comply or use the Compliance Checker.
2. Inventory in-scope AI systems and classify them by role (developer/deployer) and decision type.
3. Address each obligation:
   • governance — Publish a written frontier AI safety framework describing how the developer assesses and mitigates catastrophic risks from frontier AI models, with periodic updates.Cal. Bus. & Prof. Code § 22757.12
   • transparency — Publish a transparency report before or concurrently with deploying a new frontier model; large frontier developers must include summaries of catastrophic-risk assessments and mitigation steps.Cal. Bus. & Prof. Code § 22757.12(c)
   • documentation — Report critical safety incidents to the California Office of Emergency Services within statutory timeframes.Cal. Bus. & Prof. Code § 22757.13
   • governance — Preserve covered-employee whistleblower rights and maintain the required notice and anonymous internal disclosure process for catastrophic-risk reports.Cal. Lab. Code § 1107.1
4. Adopt a federal control framework: NIST AI RMF or ISO/IEC 42001 to demonstrate due care.
5. Document evidence of compliance for each obligation, refreshed at the cadence the law requires.
6. Build the AG-notification path if the law requires it (Colorado, California SB 53).
7. Set the refresh cadence — annual for most impact-assessment regimes; continuous for monitoring.