Scope and Application

All proposals focus on "frontier" or advanced AI systems, but define the threshold differently. California and New York both use $500M revenue thresholds. The Blackburn bill uses FTC-established thresholds ($500M revenue or 1M+ individuals' data processed). Sanders' moratorium applies to infrastructure rather than models.

The pre-deployment vs. post-deployment question is one of the sharpest divides. OpenAI advocates pre-deployment testing (prevention model). California SB 1047 attempted this but was vetoed; SB 53 retreated to post-deployment transparency. The Blackburn bill creates an evaluation program but the mandatory testing scope is ambiguous. Sanders' moratorium is the most aggressive pre-deployment intervention, stopping the infrastructure itself. The White House framework leans post-deployment (enforcement of existing laws).

Most proposals are horizontal, applying across sectors. Kelly's NDAA provisions are a notable exception, targeting military AI specifically. The Blackburn bill includes sector-specific provisions for children's platforms alongside horizontal obligations.