Estimated training compute
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- BelowEU Commission guidelines (indicative): >1023 FLOPPresumption that a model is general-purpose, if it can also generate language, images or video. Non-binding guidance.
- BelowEU AI Act, Article 51: >1025 FLOPPresumption of systemic risk; notice within two weeks. In force.
- BelowCalifornia SB 53: >1026 operations, including fine-tuning“Frontier model” duties. In force January 1, 2026.
- BelowNew York RAISE Act: >1026 operations“Frontier model” duties. Takes effect January 1, 2027.
- BelowSouth Korea AI Basic Act decree: ≥1026 FLOP“High-performance AI” safety duties. In force January 22, 2026.
- BelowS. 2938 (proposed): >1026 operationsMandatory federal evaluation before deployment. Introduced September 29, 2025.
This is a rough estimate. Estimates by outsiders can be off by a factor of two or more, and the laws put the duty on the developer, who knows its own numbers. California counts fine-tuning and later modifications toward the total. New York and California add a revenue test, so the heaviest duties fall on companies above $500 million.
Crossing a binding line triggers notice, documentation or safety duties. The 1023 line is non-binding guidance, and S. 2938 is a bill, not law. None of the enacted laws listed requires a government license before training a frontier model. Thresholds and statuses are stated as of October 2026. General information, not legal advice. Sources and method: compute thresholds.