The EU Lead
EU AI Act is the most comprehensive. High-risk enforcement August 2, 2026. Other jurisdictions watch and adapt.
US State Patchwork
California (CPRA + proposed AI laws), New York (bias audit for HR AI), Illinois (biometric). Federal action stalled; state action proliferates. Multi-state compliance gets complex.
UK AI Bill
UK takes a sectoral approach — regulate AI by use (financial, healthcare, employment) rather than overarching AI Act. 2026 status: framework published, specific rules maturing.
China AI Rules
Algorithmic recommendation regulations, deep synthesis rules, generative AI measures. Different posture from EU — government direction rather than enumerated rights. Multinational CRM deployments must navigate.