Virginia has become the first state in 2025 to pass comprehensive artificial intelligence regulation, with lawmakers approving the "High-Risk Artificial Intelligence Developer and Deployer Act" (HB 2094). The legislation, which passed by narrow margins in both chambers, establishes regulatory frameworks for AI systems making consequential decisions in education, employment, financial services, health care, and legal services. Governor Glenn Youngkin has until March 24 to sign, veto, or return the bill with amendments, and if approved, the law would take effect July 1, 2026.

The legislation requires developers to disclose risks, limitations, and intended purposes of high-risk AI systems, along with performance evaluation summaries and measures to mitigate algorithmic discrimination. Deployers must exercise a "reasonable duty of care" and implement risk management policies, with violations potentially carrying civil penalties between $1,000 and $10,000 under the enforcement authority of the Virginia Attorney General. Notably, compliance with established standards like NIST's AI risk management frameworks or ISO/IEC 42001 is deemed sufficient to meet the bill's requirements.

As other states develop their own approaches—Connecticut reintroducing an AI guardrails bill and New Mexico proposing anti-algorithmic discrimination legislation—Virginia's approach could serve as a significant reference point in the evolving landscape of state-level AI governance.