What is the EU AI Act and how does it affect non-European companies?

The EU AI Act is the world's first comprehensive horizontal AI regulation, establishing risk-tiered obligations for AI systems. Like GDPR, it applies based on where users are located, not where providers are based — meaning non-European companies that deploy AI systems to EU users are subject to its requirements, including documentation, transparency, and conformity assessments for high-risk systems.

What is general-purpose AI and why is it harder to regulate?

General-purpose AI (GPAI) refers to foundation models trained to perform a wide range of tasks, such as GPT-4, Claude, or Gemini. They are harder to regulate because they are not designed for a single use case, making it impossible to fully anticipate all downstream applications at the time of regulation. This breaks the traditional regulatory strategy of governing AI at the point of use.

How do AI regulations differ between the US, EU, and China?

The EU uses a risk-tiered compliance model grounded in fundamental rights. The US uses a sector-specific, largely voluntary principles-based approach focused on innovation. China uses a sovereignty-first model with targeted regulations emphasizing state oversight and content control. These reflect fundamentally different views about what AI governance is for.

Is there a global AI governance framework?

Not yet. While international efforts like the Bletchley Declaration, OECD AI Principles, G7 Hiroshima AI Process, and the Council of Europe's AI Convention represent meaningful progress in norm-setting, they are mostly non-binding and fragmented. Real harmonization of AI regulation across major jurisdictions is likely a decade or more away.

What should organizations do to navigate cross-border AI regulation?

Organizations should map which jurisdictions their AI systems touch and which regulatory regimes apply. They should invest in governance documentation, understand liability in their AI supply chains, conduct vendor due diligence on AI tools they procure, and build compliance programs flexible enough to adapt as the regulatory landscape continues to evolve.

Policy & Regulation 11 min read

Regulating Artificial Intelligence Across Borders

Jared Clark

March 27, 2026

Last updated: 2026-03-27

Jared Clark

Founder, Prepare for AI

Jared Clark is the founder of Prepare for AI, a thought leadership platform exploring how AI transforms institutions, work, and society.

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