Have you ever wondered how the UK and the US are tackling the fast-moving world of artificial intelligence (AI)?

It turns out they’re taking a pretty similar approach—one that focuses on guiding principles and existing regulations rather than creating a single, giant AI law. Below, we’ll explore what that means, and then we’ll see how this compares to what the EU has been up to on the AI front.

A Regulator-Led Approach

First things first: neither the UK nor the US has passed a comprehensive “AI Act.” Instead, they’re both relying on regulators in each industry—like finance, healthcare, and data protection—to keep an eye on AI. In the UK, for instance, you’ve got the Information Commissioner’s Office (ICO) and the Competition and Markets Authority (CMA) working on specific AI issues within their respective fields. Meanwhile, across the pond, agencies like the Federal Trade Commission (FTC) and the Food and Drug Administration (FDA) are using existing laws to address any AI-related concerns in the US.

This isn’t just about convenience. Policymakers argue that a single, all-encompassing AI law would be too slow to adapt. AI tech changes practically every week, so these officials believe it’s better to let each sector shape its own guidelines as the technology evolves.

Keeping Innovation Alive

Innovation is the big buzzword on both sides of the Atlantic. Nobody wants to scare off AI startups or discourage well-established companies from exploring new AI tools. By opting for a lighter, more flexible touch, the UK and the US hope to stay competitive and draw in AI investment. After all, if regulations become too strict or complicated, there’s a real possibility that companies could simply pick up and move to friendlier markets.

That’s why in the UK you’ll find policy papers like the AI Governance White Paper laying out general principles. But don’t expect a sweeping new law.

Why Not a Single AI Law?

So why are both countries going down this path? One big reason is that AI is popping up in so many different places. Think about it: the same technology that scans medical images can also help a bank decide if you’re eligible for a loan. It’s pretty tough to design one set of rules that works perfectly in both finance and healthcare. Sector-by-sector guidelines feel more nimble and relevant—at least that’s what the UK and the US are betting on.

Another factor is the sheer pace of AI advancements. If you lock in strict rules today, there’s a good chance they’ll need a major overhaul next year, if not sooner. By letting regulators handle things, governments can tweak guidelines as new uses for AI emerge.

A Quick Look at the EU

Meanwhile, the European Union is taking a different route with its AI Act. This legislation sorts AI systems into categories based on how risky they might be—for instance, things like law enforcement facial recognition could face tougher rules than more routine AI applications. If a system is deemed “high-risk,” it needs to meet strict requirements around transparency, data quality, and human oversight. Some AI uses might even get banned altogether, especially if they involve real-time remote biometric identification in public areas.

The EU’s mindset is that strong, centralised rules will protect people and businesses across all its Member States. Critics, though, argue that this “one-size-fits-all” approach might stifle innovation and be too expensive or complicated for smaller companies to handle.

Wrapping Up

So there you have it. The UK and the US are taking a more open-ended, adaptable road when it comes to AI rules, hoping it’ll foster innovation and keep their markets attractive to tech companies. The EU, on the other hand, wants a firm set of comprehensive rules to address potential dangers up front. Which approach will prove most effective? Only time—and the rapid evolution of AI—will tell.