Businesses deploying AI systems across borders face a fragmented regulatory environment in which the European Union enforces strict compliance mandates, China prioritises state oversight, and the United States operates under a patchwork of state-level and sector-specific rules. This guide maps the current global AI regulation terrain and provides actionable compliance steps for organisations operating internationally.
AI regulations are legal frameworks that govern the development, deployment, and monitoring of artificial intelligence technologies. These rules establish requirements for safety, transparency, accountability, and data protection across the AI lifecycle.
By early 2026, over 72 countries have launched more than 1,000 AI policy initiatives. The scope varies dramatically, from binding legislation with heavy penalties to voluntary guidelines with no enforcement mechanism.
Key regulatory focus areas include:
• Safety requirements for risky AI systems
• Transparency obligations for AI-generated content
• Data governance aligned with data protection laws
• Accountability frameworks for AI developers and deployers
For businesses operating across multiple jurisdictions, understanding which AI law applies, and when, determines whether you face routine compliance or penalties reaching 7% of global revenue.
The EU AI Act is the world’s first comprehensive AI law, entering into force on August 1, 2024. It defines AI as a machine-based system that infers outputs from inputs to influence physical or virtual environments.
The Artificial Intelligence Act uses a four-tier risk classification:
1. Unacceptable risk – Banned outright (social scoring, certain biometric identification)
2. High risk – Strict compliance obligations (employment, education, law enforcement)
3. Limited risk – Transparency requirements (chatbots, AI-generated content)
4. Minimal risk – No specific obligations
The United States lacks comprehensive federal legislation on AI. Instead, regulation of artificial intelligence occurs through agency-specific guidelines and a growing body of state-level AI regulation.
A December 2025 White House executive order established a national AI policy framework designed to:
• Preempt conflicting state laws
• Evaluate regulations that compel AI models to alter truthful outputs
• Promote AI innovation with minimal regulatory burden
The Federal Trade Commission and the SEC issue sector-specific guidance. The SEC’s September 2024 AI Compliance Plan addressed financial market risks without imposing binding mandates.
States have moved faster than the federal government:
• Utah – Artificial Intelligence Policy Act requires clear disclosures for generative AI consumer interactions
• Colorado – Enacted a comprehensive AI law addressing automated decision systems
• California – Established disclosure requirements for certain AI applications
This fragmented approach creates compliance challenges. Businesses must monitor developments as the incoming administration signals softer federal enforcement in favour of economic growth.
The UK pursues a “compliance-lite” strategy, positioning itself as a leader in responsible AI development without adopting the EU’s prescriptive penalties.
The AI Opportunities Action Plan emphasises:
• Data centre expansion and tech hub development
• Public-private partnerships for AI services
• Light-touch AI safety regulations aligned with economic growth
Rather than creating a central AI authority, the UK relies on existing sectoral regulators applying five cross-sectoral principles for AI governance. A £100 million investment supports regulator capacity.
Under the Labour government, a planned Frontier AI Bill may introduce targeted rules for the most capable AI models, though it stops short of EU-style horizontal regulation.
China’s approach to AI regulation reflects its broader governance model: centralised state oversight, mandatory ethical reviews, and content-control requirements. Rules in China mandate that AI-generated content aligns with state values and include measures for labelling synthetic media.
The foundation dates to the 2017 National AI Development Plan, which set goals for global AI leadership by 2030. Since then, China has enacted specific rules for:
• Generative AI services – Over 100 approved by mid-2025
• Algorithmic recommendations – Transparency and user control requirements
• Deepfakes and synthetic media – Mandatory labelling and watermarking
The Measures for Labelling AI-Generated and Synthetic Content, effective September 2025, require platforms to implement detection mechanisms, including audio Morse codes, encrypted metadata, and VR-based watermarking systems.
An amended Cybersecurity Law, which explicitly references AI, became enforceable on January 1, 2026, adding requirements for AI security reviews and data localisation.
A draft Artificial Intelligence Law proposed in May 2024 could, if enacted, formalise binding requirements for high-risk systems, potentially creating a comprehensive AI law equivalent in China. China’s National Technical Committee 260 on Cybersecurity released the AI Safety Governance Framework in September 2024, introducing guidelines for the ethical and secure development of AI technologies.
Japan’s approach emphasises voluntary self-regulation rather than binding mandates.
The Act on the Promotion of Research and Development and Utilisation of AI-Related Technologies (AI Promotion Act), enacted in May 2025 and effective in June 2025, establishes a non-binding framework focused on:
• Strategic coordination across government agencies
• Transparency goals for AI systems
• R&D promotion for manufacturing, healthcare, and robotics
Japan also shaped international norms through the 2023 Hiroshima Guiding Principles for global AI safety, developed during its G7 presidency.
Singapore pioneered AI governance with the world’s first Model AI Governance Framework in 2019.
The city-state maintains regional leadership through rapid policy updates:
• 2024 generative AI guidelines for financial services
• Ongoing collaboration with industry on trustworthy AI standards
• Practical toolkits for organisations implementing responsible AI practices
Singapore’s framework serves as a model for other Asia-Pacific nations developing their own AI initiatives.
Australia released voluntary AI safety standards and a National AI Plan emphasising ethical AI deployment in government services.
Canada’s proposed Artificial Intelligence and Data Act (AIDA) would establish a risk-based regulatory framework with requirements for high-risk AI applications. The AI bill remains under parliamentary consideration.
Brazil is developing risk-based AI regulation proposals modelled partly on the EU approach, though with adaptations for its domestic context.
Middle East nations are investing heavily in AI development:
• Saudi Arabia’s national AI strategy focuses on diversifying the economy through AI adoption
• UAE’s AI Strategy 2031 targets becoming a global AI leader with dedicated government ministries
Several international bodies work toward harmonised standards for the trustworthy development of AI systems.
OECD AI Principles (updated 2024) – Provide foundational guidance for trustworthy AI across 44 member countries. The principles address transparency, accountability, and robustness.
Global Partnership on AI (GPAI) – A multi-stakeholder forum with 44 member countries coordinating on responsible AI development, AI research priorities, and governance best practices.
Council of Europe Framework Convention – The first legally binding international AI treaty, establishing baseline requirements for human rights protection in AI deployment.
UN AI Advisory Body – Leading discussions on global AI governance frameworks, with UNESCO convening regional summits on ethical AI standards.
These initiatives support convergence but cannot eliminate jurisdictional differences that businesses must navigate.
Despite regulatory fragmentation, common themes emerge in how jurisdictions regulate AI:
Risk Assessment and Classification
• Identify where AI applications fall on risk scales
• Document justifications for classifications
• Conduct risk assessments for high-risk systems
Data Governance
• Align AI training data practices with data privacy requirements
• Implement data protection measures for personal information
• Address intellectual property protection in training datasets
Transparency and Explainability
• Disclose AI use to affected individuals
• Document decision-making logic for high risk ai systems
• Label AI-generated content appropriately
Human Oversight
• Establish human review for consequential AI decisions
• Implement AI oversight mechanisms
• Create escalation procedures for AI failures
Bias Testing and Fairness
• Evaluate AI models for discriminatory outcomes
• Address AI bias through testing and mitigation
• Document fairness evaluation procedures
Map your AI systems against regulatory requirements in each jurisdiction where you operate. Identify which rules apply based on where AI is developed, deployed, and whose data it processes.
Build systems to track regulatory changes and assess ongoing compliance. The EU AI Act alone has multiple implementation dates through 2027.
AI compliance intersects with existing data protection legal frameworks. Establish clear practices for sourcing training data, handling personal data, and cross-border transfers.
High-risk AI systems require documented procedures for addressing failures, bias discoveries, and security incidents. Build corrective action processes before problems arise.
AI literacy requirements under the EU AI Act represent broader expectations that staff understand AI risks and obligations. Invest in training programs covering regulatory requirements and responsible use principles.
Organisations managing AI deployment across borders need integrated compliance strategies that address multiple regulatory frameworks simultaneously.
GDPRLocal provides:
• AI governance consulting – Readiness assessments aligned with the EU AI Act and other major frameworks
• Cross-border compliance strategy – Coordinated approaches for multi-jurisdiction operations
• Integration with data protection – Linking AI compliance services with existing GDPR and data privacy programs
• Regulatory monitoring – Tracking global AI regulatory developments affecting your operations
Our expertise in managing AI risks helps organisations implement practical compliance without unnecessary operational burden.
This depends on where your AI systems are developed, deployed, and whose data they process. The EU AI Act applies if you place AI on the EU market or deploy AI affecting people in the EU, regardless of where your company is headquartered.
The EU AI Act imposes fines up to €35 million or 7% of global annual turnover. Other jurisdictions have lighter penalties or none; Japan’s AI Promotion Act has no enforcement mechanism, while U.S. penalties depend on which agency takes action under existing consumer protection or securities laws.
Start with the most stringent requirements you’ll face (typically the EU AI Act for companies operating in Europe). Document your AI systems, classify risks, and build governance processes that adapt as regulations evolve.