LibraryFraud centerFraud learnHow countries around the world approach the creation of legal frameworks on artificial intelligence (AI)

How countries around the world approach the creation of legal frameworks on artificial intelligence (AI)

With many countries in the process of discussing or already moving forward with legislation to govern the use of artificial intelligence, we have pulled together the most important information you need to know on how key economies approach the regulation of AI

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Aleksander Tsuiman
Head of Regulatory Compliance
December 27, 2023
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Global perspective on the legal frameworks on artificial intelligence (AI)

AI ethics concerns have taken center stage as AI systems become more integrated into our daily lives.

According to Stanford’s 2023 “The AI Index Report,” the legislative records of 127 countries show that the number of bills containing the term “artificial intelligence” passed into law grew from just 1 in 2016 to 37 in 2022. An analysis of the parliamentary records on AI in 81 countries likewise shows that mentions of AI in global legislative proceedings have increased nearly 6.5 times since 2016.

Why is that? There are increasing ethical questions around AI systems as there is a growing deployment of, and research around, AI systems due to increased availability. The ethical issues imposing high risks around AI that negatively affect safety or fundamental rights have become more apparent to the general public. Meanwhile, startups and large companies are in a race to deploy and release newer and more powerful AI models, for example around generative AI.

Policy-level effect. The growing popularity of AI has led to intergovernmental, national, and regional organizations taking steps towards AI governance on a strategic and operational level. Governments are increasingly motivated by addressing the rising societal and ethical concerns in order to create trust and maximize the technology’s benefits. Therefore, the governance of AI technologies has become essential for governments across the world.

Potential risks of regulation. The surge in AI regulation does also come with risks. One is the challenge of finding a balance between empowering trust and ensuring safety versus overregulation turning into stifled innovation and economic standstill. This is also the reason why some governments, e.g. the UK and US, have been rather conservative in taking bold and aggressive moves towards regulation. The other potential pitfall for companies is a regulatory patchwork which makes market entry difficult resulting in companies shying away from expansion. This is where intergovernmental and international alignment is needed - as the driver is often economic synergy then bodies like the US-EU Trade and Technology Council have the potential to bring down hurdles for businesses seeking to operate across borders by creating policy-level alignment.

United States

The US does not currently have a uniform “AI law” as compared to what is about to be adopted in the EU. Although the intent for AI regulation in the US is accelerating then not many initiatives have succeeded in the legislature. There is also an increased level of activity on state-level with different states intending to regulate different aspects of AI, for example, California Assembly Bill No. 302.

Although the US lacks a comprehensive AI regulatory framework, there is a strong sentiment by the US authorities that AI-related issues, e.g. bias and potential discrimination, can and should be enforced under the current legislative framework. On the 25th of April 2023, a “Joint Statement on Enforcement Efforts Against Discrimination and Bias in Automated Systems” was released by the Federal Trade Commission, Consumer Financial Protection Bureau, Department of Justice’s Civil Rights Division, and Equal Employment Opportunity Commission. According to the statement, the authorities promise to vigorously enforce their collective authorities and to monitor the development and use of automated systems.

There are also a couple of initiatives that give a strong sentiment on the intended policy direction and also create certain regulatory obligations. For example, the White House did release “Blueprint for an AI Bill of Rights” in October 2022. However, this is currently a non-binding roadmap for the responsible use of AI systems then this does offer good guidance on what entities can expect with regard to future laws affecting AI usage in the US. 

Secondly, on a more important note, on the 30th of October 2023,  President Biden released his long-awaited Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence.With the Executive Order, the President directs actions to protect Americans from the potential risks of AI systems to strengthen the nation's capabilities in artificial intelligence (AI), to promote scientific discovery, economic competitiveness, and national security.

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United Kingdom

The Department for Science, Innovation and Technology published a white paper on 29 March 2023 titled "AI Regulation: A Pro-Innovation Approach", which sets out the UK Government’s proposals to regulate artificial intelligence (AI) in a pro-innovation manner. The paper acknowledges the potential benefits of AI, such as improving healthcare, enhancing transport systems, and boosting economic productivity, while also recognizing the potential risks and challenges associated with this emerging technology.

Currently, the UK does not have a comprehensive AI regulation in place and first-hand it seems that there is not a serious one on the horizon. However, the UK government intends to give more powers to the existing sector-specific regulators to approach the AI risks around the following 5 principles: (i) safety, security and robustness; (ii) appropriate transparency and explainability; (iii) fairness; (iv) accountability and governance; and (v) contestability and redress.

The UK government confirmed that it will avoid “heavy-handed legislation” to avoid hindering the ability to respond to technological advances, and will instead “take an adaptable approach to regulating AI”, allowing regulators to use their expertise to modify the implementation of the principles to suit the specific context of AI in such regulator’s respective sector. The regulators will likely have a duty to apply the principles in case they are unable to implement and enforce them voluntarily. Key regulators are being encouraged to issue further guidance and resources on how to implement the five principles and how the principles will apply within their specific sectors. However, there are likely to be some gaps between the various approaches by regulators, and therefore, it is possible that legislation may be required to ensure consistent consideration of the principles.

The UK also wants to empower and harness the innovative power of AI, therefore, it has also confirmed the introduction of  AI regulatory sandboxes. 

What has been interesting to see lately is the UK's growing interest towards existential risks deriving from AI, especially at the frontier of development. The UK has taken a very active role in discussing how such risks can be mitigated through internationally coordinated action. A good example of this was the 2023 AI Safety Summit which took place in the beginning of November at Bletchley Park and which ended with the Bletchley Declaration on AI safety. Although there is presumably no effect on the majority of the businesses in the short term deriving from this it is still worthwhile monitoring the direction of the policy.


In April 2021, the European Union´s Commission proposed the first comprehensive framework to regulate the use of AI. The EU’s priority is ensuring that AI systems used in the EU are safe, transparent, traceable, non-discriminatory, and environmentally friendly.

Like the EU’s General Data Protection Regulation (GDPR) in 2018, the EU AI Act could become a global standard, determining to what extent AI has a positive rather than negative effect. The EU’s AI regulation is already making waves internationally and you can read more about it in our previous blog.

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