Correction (19 October 2026): This index has been updated to mark Executive Order 14110 as revoked (January 2025), Canada's AIDA as lapsed (January 2025) and the legislative status of Brazil's bill, and to correct the descriptions of the EU AI Act's predictive-policing ban, the Bletchley Declaration's signatories and focus, the standing of the AI Bill of Rights Blueprint, the Algorithmic Accountability Act's status and the title of the UK White Paper.
Scope and Enforcement Power Index
Compares how binding each major jurisdiction's AI rules are and how severe its penalties are.
Regulatory Approach Models
- Risk-Based (EU; Canada's lapsed AIDA bill): Focuses on the risk created by the specific use case, not the technology itself.
- Sectoral/Distributed (US): Relies on existing agencies issuing guidance in their own fields rather than on a single umbrella law.
- State & Content Control (China): Focuses on the ideological integrity of generated synthetic content and mandatory algorithm registration.
- Principle-Based (OECD, UNESCO): Non-binding ethical frameworks that serve as a reference point for national laws.
Key Milestones
A
Algorithmic Accountability Act (Draft)
United StatesAnalysis: This bill, which would give the Federal Trade Commission (FTC) sweeping powers at the federal level, requires companies to conduct an "Impact Assessment" of the decision-making algorithms they use. Its aim is transparent reporting on whether those algorithms discriminate by race, gender, or age, particularly in areas that directly affect people's lives, such as recruitment, lending, housing, and education.
Set against the general US reluctance to regulate, the bill is the most concrete legislative step yet toward addressing how "black box" systems harm consumers. If it becomes law, tech companies will have to explain to the FTC how their algorithms are trained.
Key Takeaways
- Focus: Consumer rights and Algorithmic Bias.
- Enforcement Power: Direct investigative and enforcement powers for the FTC.
- Status: Not enacted; versions have been introduced in several Congresses since 2019 without passing.
Artificial Intelligence Act (EU AI Act)
European UnionAnalysis: The world's first comprehensive, legally binding horizontal artificial intelligence law. It was adopted in June 2024 and entered into force in August 2024, with a phased transition. The law sorts AI into four tiers according to the risk it creates (the risk-based approach) rather than the technology itself: Unacceptable Risk, High Risk, Limited Risk, and Minimal Risk.
The law's most significant feature is the "Brussels Effect": a US or Chinese company that wants to sell a product in the European market must comply with its rules. Social scoring, subliminal manipulation, and unauthorized biometric categorization are banned outright, while General Purpose AI (GPAI) and Large Language Models (LLMs) are subject to transparency, copyright compliance, and systemic risk reporting obligations.
Key Takeaways
- Penalty Architecture: Fines of up to 7% of global turnover (or 35 Million Euros) for violations.
- Banned Systems: Social scoring is banned, as is predicting an individual's risk of offending based solely on profiling or personality traits (Art. 5(1)(c)-(d)).
- GPAI Models: "Systemic risk" auditing for models like GPT-4.
Artificial Intelligence and Data Act (AIDA - Bill C-27)
CanadaAnalysis: AIDA, part of Canada's Bill C-27, departs from the European model and follows the logic of "Agile Regulation." Rather than regulating AI systems in detail, it sets a framework only for "High-Impact" systems and leaves the details to future regulations.
AIDA's most striking feature is a new executive office, the "AI and Data Commissioner." Although the bill initially favored guidance so as not to stifle innovation, it stood out for proposing to bring malicious and harmful uses of AI directly within the criminal law, with heavy penalties including imprisonment.
Key Takeaways
- Status: Died on the Order Paper when Parliament was prorogued on 6 January 2025; never enacted.
- High-Impact AI: Focus on systems affecting human life.
- New Authority: AI Commissioner with broad auditing powers.
- Criminal Law: Prison sentences for individuals who knowingly use data or models in dangerous ways.
B
Bill No. 2338/2023 (Artificial Intelligence Law)
BrazilAnalysis: This bill, the Global South's boldest step in technology regulation, combines the risk-based approach of the EU AI Act with Brazil's own case law. It contains particularly strong provisions on the labor market, racial discrimination, and the right to challenge algorithmic decisions (Human in the Loop).
The most notable aspect of the Brazilian bill is its clear position on copyright. It proposes new mechanisms under which AI companies would pay royalties to content creators for copyrighted works used in data mining and AI training. As introduced in 2023, it also made providers and operators of high-risk and excessive-risk AI systems strictly liable for the damage they cause.
Key Takeaways
- Status: Approved by the Federal Senate on 10 December 2024 and sent to the Chamber of Deputies for review in March 2025.
- Liability: Strict liability for high-risk systems in the 2023 text; the final regime depends on the text ultimately enacted.
- Copyrights: Obligation for AI companies to pay authors.
- Human Agency: The right to demand human review of any algorithmic decision.
Bletchley Declaration
Global (UK Led)Analysis: Agreed by 28 countries and the European Union, including the US, China and Turkey, at the summit held in November 2023 at Bletchley Park (UK), where the Enigma codes were broken during WWII; New Zealand joined in October 2024. Although it is not legally binding, it marked a turning point in global AI diplomacy.
The declaration focuses on the risks posed by "Frontier AI" models, particularly in domains such as cybersecurity and biotechnology, while also acknowledging everyday harms such as bias, privacy and data protection. Because geopolitical rivals such as China and the US signed the same text, it became the first global agreement to record officially that AI safety is a transnational challenge that transcends politics.
Key Takeaways
- Nature: A non-binding declaration of diplomatic goodwill.
- Focus: Frontier AI risks (notably cybersecurity and biotechnology), while also acknowledging everyday harms such as bias and privacy.
- Significance: One of the few texts on technology signed jointly by the US and China.
Blueprint for an AI Bill of Rights
United StatesAnalysis: Published by the White House Office of Science and Technology Policy (OSTP), this document does not have the force of law, but it sets out the philosophical foundation of the US government's approach to AI. It is built around five core principles: Safe and Effective Systems, Algorithmic Discrimination Protections, Data Privacy, Notice and Explanation, and Human Alternatives, Consideration, and Fallback.
Its most significant element is the emphasis on the "Opt-Out" right and on the citizen's right to speak to a human rather than a bot (Human Fallback). A non-binding OSTP framework published in October 2022, it influenced agency guidance under the previous administration; it was archived after the change of administration in January 2025 and no longer reflects federal policy.
Key Takeaways
- Fundamental Right: The right of people not to be victimized by machines.
- Human Alternative: The ability to reject AI in critical decisions and ask for a human decision-maker.
- Privacy: The principle that citizens' data should be protected by default.
C
Council of Europe Framework Convention on AI
Council of EuropeAnalysis: It is the "world's first legally binding international treaty" on artificial intelligence. Whereas the EU AI Act is essentially a market regulation, the Council of Europe convention is written from the perspective of human rights, democracy, and the rule of law.
Opened for signature in September 2024, the convention obliges signatory states to enact national laws that prevent AI from undermining the judicial system, democratic processes (e.g., through election manipulation), and human rights. The main point of contention is that national security and defense applications are excluded from the convention's scope altogether.
Key Takeaways
- Scope: Alignment with the European Convention on Human Rights (ECHR) rather than market dynamics.
- Bindingness: Binding under international law on signatory countries.
- Non-Parties: Open not only to European states but also to observer states such as the US and Israel.
E
Executive Order 14110 on Safe, Secure, and Trustworthy AI
United StatesAnalysis: Signed by US President Joe Biden in October 2023 and revoked on 20 January 2025 by Executive Order 14148, this Executive Order (EO) directed federal agencies across government (Defense, Energy, Commerce, Health) to set AI standards, as a way around a slow-moving Congress. It is the clearest sign that the US has chosen a sectoral, distributed approach to AI governance over a single central law.
The most striking legal mechanism of the EO was its use of the Defense Production Act to require companies developing powerful AI models (such as OpenAI and Google) to report to the US government, among other things, the results of their safety testing (Red-Teaming). Since its revocation, US federal AI policy has been shaped by EO 14179 (January 2025), America's AI Action Plan (July 2025) and EO 14365 (December 2025) on a national policy framework for AI.
Key Takeaways
- Status: Revoked on 20 January 2025 (EO 14148); listed here as a historical instrument.
- Method: Distributed regulation. Each federal agency audits its own sector.
- Red-Teaming: Testing models to ensure they cannot be used to develop cyber or biological weapons.
- National Security: Using defense-production powers over commercial software companies.
G
Generative AI Services Management Interim Measures
People's Republic of ChinaAnalysis: In force since August 2023, this regulation is one of the world's first legal texts to regulate "Generative AI" specifically. Enforced by the Cyberspace Administration of China (CAC), it is built on "Content Control and Ideological Integrity," a sharp departure from the West's risk-based approach.
Article 4 stipulates that generative AI must "adhere to core Socialist values" and not generate content aimed at subverting state power or disrupting national unity. It also requires AI providers to file their algorithms in a state database and to undergo security assessments. While it allows flexibility for research, it sets up a strict state censorship and surveillance infrastructure for public-facing uses.
Key Takeaways
- Ideological Filtering: Obligation for LLM outputs to comply with state political doctrines.
- Filing Obligation: Registering algorithms in the state's central Algorithm Registry.
- Training Data: Proving to the state that the data used is "legitimate" and respects intellectual property.
I
Internet Info. Service Algorithmic Recommendation Provisions
People's Republic of ChinaAnalysis: A narrowly targeted law (2021/2022) that regulates the "Recommendation Algorithms" underlying platforms such as TikTok (Douyin) and Taobao, not just AI models. It is a direct state intervention against algorithmic designs that exploit users' attention and foster addiction.
The law requires companies to give users the right to "completely turn off the algorithmic recommendation system." It also expressly prohibits programming algorithms in ways that exploit platform workers (couriers, drivers) or endanger their physical health. Using algorithms for excessive pricing or anti-competitive (monopolistic) conduct attracts administrative sanctions.
Key Takeaways
- Right to Turn Off: Users can demand a chronological feed instead of an algorithm.
- Workers' Rights: Algorithms may not push couriers to superhuman speeds.
- Anti-Monopoly: Preventing algorithms from being used to wipe competitors out of the market.
O
OECD Principles on Artificial Intelligence
Global (OECD)Analysis: Adopted in May 2019 and updated in 2024, these principles were the first intergovernmental standard on artificial intelligence. They have been adopted by over 40 countries, including the US, the EU, and Turkey. Although they are not legally binding (Hard Law), they serve as the primary blueprint (Soft Law) for national AI strategies worldwide.
They rest on five core principles: Inclusive growth/sustainable development, Human-centered values/fairness, Transparency/Explainability, Robustness/Security, and Accountability. The fact that even the AI definition in the EU AI Act is taken directly from the technical definition formulated by the OECD (2023 update) shows how influential these principles are in international law.
Key Takeaways
- Impact: Created a common terminology and "AI Definition" for global laws.
- Focus: Introduced the concept of "Trustworthy AI" into international discourse.
- Accountability: Actors remain accountable throughout a system's entire lifecycle.
P
Pro-innovation approach to AI regulation (UK White Paper, March 2023)
United KingdomAnalysis: The main strategy document showing that, after Brexit, the UK has parted ways with the EU and drawn up its own digital roadmap. Rejecting the EU's rigid, centralized "AI Act" model, the UK adopts a "Context-specific" and "Pro-innovation" approach rather than creating a new AI regulator. The government confirmed this approach in its February 2024 response to the White Paper consultation.
Under this approach, the existing health regulator (MHRA) will regulate AI used in healthcare, and the financial regulator (FCA) AI used in finance, each on the basis of its own principles. Instead of imposing heavy bans, the government sets 5 core principles (Safety, Transparency, Fairness, Accountability, Contestability) and builds a "light-touch" legal framework that encourages companies to innovate in regulatory sandboxes.
Key Takeaways
- Approach: Decentralized. Opposes the creation of a central AI regulator.
- Competitive Advantage: A strategy to attract to London tech companies fleeing the EU's strict laws.
- Flexibility: Relies heavily on guidance from regulators rather than on new legislation.
U
UNESCO Recommendation on the Ethics of AI
Global (United Nations)Analysis: Adopted by UNESCO's 193 member states in 2021, it is the global standard on AI ethics with the widest participation. It is a normative instrument that addresses not only technological development but also AI's effects on cultural diversity, the environment, education, and gender equality.
The recommendation advises states to establish "Ethical Impact Assessment" methodologies. At its core lies the philosophy that "Technological development cannot proceed at the expense of human rights and nature." Although it is not legally binding, it provides a direct blueprint for draft legislation in countries, for example in Africa and Latin America, that have not yet enacted their own AI laws.
Key Takeaways
- Inclusivity: Looks at technology from the perspective of the Global South and of culture, not just from a Western one.
- Gender: Dedicates a special section to eliminating the biases of AI algorithms against women and minorities.
- Environment: Treats AI's climate and carbon-emission costs as an ethical issue.