Compliance Stuff

On December 11, 2025, President Trump  signed an executive order   purporting to limit the ability of states to regulate the use of artificial intelligence (AI) . The order’s stated purpose is to ensure that American AI companies are “free to innovate without cumbersome regulation” and to “remove barriers to American AI leadership.” The order cites the proliferation of AI legislative proposals in state legislatures as undermining that goal (although it bears note that few if any of these proposals have or are likely to become law). The order specifically cites as problematic a recently enacted California state law, which it claims requires “complex and burdensome disclosure… based on the purely speculative suspicion that AI might ‘pose significant catastrophic risk.’” It further references Colorado state law regarding algorithmic discrimination, claiming that that law “may even force AI models to embed DEI in their programming.” The order goes on to state that the administrat...

States are playing a critical role in the development of AI policy in the United States, as serious legislative efforts at the federal level remain stalled. The Trump Administration and Republican Congress have signaled they plan to take a business-friendly, light-touch approach to AI regulation that prioritizes American innovation and emphasizes competition with China, and there is little prospect of Congress moving a substantive AI bill in the current political climate . Instead, states are moving to fill the federal void by taking up a flurry of AI bills to ensure that—amid AI innovation—regulators also create “guardrails” around uses of AI and that consumers can identify AI-generated content. Much like state legislatures, state attorneys general will likely focus on AI issues as they intersect with consumer protection concerns, including privacy. This alert focuses on the major actions that have occurred thus far in 2025 and how we expect the state regulatory landscape to act as th...