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The EU and U.S. diverge on AI regulation: A transatlantic comparison and steps to alignment

April 25, 2023

The EU and the U.S. are jointly pivotal to the future of global AI governance. Ensuring that EU and U.S. approaches to AI risk management are generally aligned will facilitate bilateral trade, improve regulatory oversight, and enable broader transatlantic cooperation.The U.S. approach to AI risk management is highly distributed across federal agencies, many adapting to AI without new legal authorities. Meanwhile, the U.S. has invested in non-regulatory infrastructure, such as a new AI risk management framework, evaluations of facial recognition software, and extensive funding of AI research. The EU approach to AI risk management is characterized by a more comprehensive range of legislation tailored to specific digital environments. The EU plans to place new requirements on high-risk AI in socioeconomic processes, the government use of AI, and regulated consumer products with AI systems. Other EU legislation enables more public transparency and influence over the design of AI systems in social media and e-commerce.