Pennsylvania House Committee Hears Frontier AI Bills on Independent Audits and Incident Reporting

Hearing Record and Legislative Status

The Pennsylvania House Communications and Technology Committee held a public hearing on HB 2800 and HB 2829 on October 19, 2026. A House Democratic Caucus release quotes the sponsors, Rep. Melissa Shusterman (HB 2800) and Rep. Manuel Guzman (HB 2829), and the chief executive of the Alliance for Secure AI. The meeting page embeds a video of the hearing but lists no testimony files. We did not review the recording, and for the testimony we also drew on a write-up by Transparency Coalition, whose analyst testified.

Both bills remain in committee. The legislature's pages for HB 2800 (referred September 23) and HB 2829 (referred October 5) list the referral as the last action and show no votes. As of October 24, committee report and Senate consideration are marked not yet reached.

What the Bill Texts Require

We read the introduced texts of HB 2800 and HB 2829. Audits and published safety frameworks apply to a “large frontier developer,” meaning one with annual gross revenue above $500 million that trained a foundation model above a compute threshold. The threshold is printed as 10^26 operations in HB 2829 and as “1,026” in HB 2800, which appears to be the same figure with its superscript lost, and Transparency Coalition reports 10^26 for both.

Starting January 1, 2028, or 90 days after a developer first qualifies, whichever is later, a large frontier developer must retain a third party each year to audit compliance. The auditor works to “generally accepted auditing standards and best practices” and needs demonstrated competence, including frontier-model safety expertise. Neither party may hold a financial interest in the other, and payment cannot depend on the result. The auditor receives “all materials reasonably necessary,” though the developer may require on-premises review or limit note taking. Within 30 days of receiving the report, the developer publishes a summary and a redacted copy and sends the copy to the Pennsylvania Emergency Management Agency (PEMA) and the Attorney General.

Any frontier developer, large or not, must report a “critical safety incident” to PEMA and the Attorney General within 72 hours of learning facts that establish a reasonable belief one occurred. An incident that poses imminent risk of death or serious physical injury goes to an appropriate authority, such as law enforcement, within 24 hours. HB 2800 defines four incident types, including loss of control causing death or injury and deceptive subversion of the developer's controls that raises catastrophic risk, and HB 2829 adds autonomous behavior, weight theft or escape, and control failure when they show increased catastrophic risk.

Only HB 2829 bars deployment when a developer's own assessments show an unreasonable risk of catastrophic-scale harm, and only HB 2829 requires test records detailed enough for an independent party to replicate the testing. Both set civil penalties for large developers of up to $1 million for a first violation and $3 million for later ones, and neither creates a private right of action.

Limits and Audit Questions

Neither bill is law, and amendments could change the introduced texts. HB 2829 takes effect January 1, 2028. Most of HB 2800 takes effect one year after notice of PEMA's temporary regulations appears in the Pennsylvania Bulletin, yet the bill names January 1, 2028 for its audit and framework duties, a tension Transparency Coalition also flags.

The caucus release states no thresholds or deadlines. It relays the Alliance for Secure AI executive's account of rogue AI models hacking companies and submitting false homicide tips to police, and we did not verify those incidents.

Our editorial audit questions: The texts name only “generally accepted auditing standards and best practices,” so which standard would an auditor apply to frontier-safety compliance, and who judges competence? What could an auditor inspect when a developer may restrict note taking and copying, and what would the public see in a redacted report? Both bills count deceptive control subversion as an incident only “outside of the context of an evaluation designed to elicit this behavior,” so how would anyone confirm how an evaluation was designed? HB 2800 counts loss of control only when it causes death or bodily injury, as Transparency Coalition's analyst also testified, so which no-injury events, such as a sandbox escape, would be reportable?

See also the Cantwell audit framework, the White House frontier controls accord, and the UK committee hearing on independent testing.