Is A Global AI Regulatory Framework Possible?
Tess Hilson-Greener
Turning HR Challenges into AI-Driven Success Stories | HR Transformation | Author of HR2035 | Writer & Speaker on AI in HR | Chief Executive Officer | BPS Board Member | Business Journalist | Advisory Board Member
Artificial Intelligence (AI) is transforming industries, economies, and societies at an unprecedented pace. However, the absence of a unified global AI regulatory framework has led to fragmented approaches across major jurisdictions. The EU, China, the US, and the UK each follow distinct strategies in AI governance, creating compliance challenges for businesses operating across borders and exposing risks of regulatory arbitrage.
This article explores how these leading economies regulate AI, highlights key gaps, and outlines what a potential global AI regulatory framework could include.
AI Regulation Across Four Key Jurisdictions
The following table compares AI laws and policies in the EU, China, the US, and the UK, highlighting areas where alignment is lacking:
Table: Global AI Regulation Comparison
This comparison highlights the diverse approaches to AI regulation across these jurisdictions, reflecting varying priorities and stages of legislative development. I have included excellent sources of Global AI Legislation below.
Notes:
Regulatory Gaps and Challenges
??No Unified Global AI Governance Body
??Potential solution: Establishing a Global AI Oversight Council under G7, UN, or OECD leadership to set baseline AI regulatory principles.
??Fragmented Technical Standards & Interoperability Issues
??Solution: Develop ISO-led global AI technical standards to ensure interoperability and alignment across markets.
??No Universal AI Risk & Ethics Framework
??Solution: A Global AI Risk Framework, similar to climate change impact assessments, could standardise risk classification.
??Weak Cross-Border AI Accountability Mechanisms
??Solution: A cross-jurisdictional AI audit & compliance mechanism would enhance oversight.
??No Standardised Public AI Registration
??Solution: A global AI transparency database for high-risk AI systems could increase public accountability.
??Lack of AI Workforce Readiness & Literacy Standards
??Solution: A UN or G20-led AI skills development framework could align education and workforce strategies.
The Path Towards a Global AI Regulatory Framework
Regulation is struggling to keep pace with AI’s rapid evolution, and while recent international efforts mark progress, they also highlight key challenges.
??Global AI Governance is Gaining Momentum
The UN’s call for a global AI governance body signals recognition of AI’s cross-border risks, but enforcing uniform standards globally remains difficult. Countries have differing priorities some focus on innovation, others on security and ethics.
??The UK’s International AI Treaty
The UK’s new AI treaty, the first of its kind, underscores growing international consensus on responsible AI. However, it primarily focuses on research collaboration and safety rather than enforceable regulation.
??US Push for AI Risk Assessments
The US is taking a more domestic approach, requiring risk assessments for AI in critical areas like national security and employment. However, without global alignment, these regulations may create compliance headaches for multinational companies.
??AI’s Evolution Outpaces Policy-Making
AI models are improving at an exponential rate, while policy is inherently slow due to political, legal, and economic constraints. By the time regulations are drafted and implemented, the AI landscape has already shifted.
??The Future: Adaptive Regulation?
The best path forward may be adaptive regulation frameworks that evolve alongside AI, rather than rigid rules that quickly become outdated. Sandboxing, real-time auditing, and AI-driven regulatory monitoring could help keep pace.
To address these gaps, a global AI governance framework should include:
?A UN-backed Global AI Council to coordinate international AI policies.
?Baseline AI safety and transparency standards, harmonised across jurisdictions.
?A unified AI risk classification system, ensuring cross-border regulatory consistency.
?A global AI ethics & accountability charter, preventing unethical AI applications.
?A multilateral AI trade agreement, ensuring fair and ethical AI development.
?AI workforce upskilling and literacy initiatives, preparing for AI-driven job transformations.
Regulation is catching up but remains reactive rather than proactive. The real test will be whether governments and international bodies can develop dynamic, enforceable, and globally harmonised regulations that balance innovation and safety.
Conclusion: A Call for Global AI Alignment
AI is borderless, but AI regulation is not. Without a global AI governance model, disparities in AI laws will lead to compliance complexity, hinder innovation, and create security risks, create compliance challenges and stifle innovation. To build a future-proof framework, governments, industry leaders, and international organisations must collaborate ensuring that not only large corporations and academic institutions are included but small businesses, AI developers, and market regulators have a voice in shaping AI governance.
Regulation Expertise
Raymond Sun has spent 2-years developing this excellent Global Regulation AI Tracker here
OECD.AI National AI policies & strategies global: This website provides a live repository of over 1000 AI policy initiatives from 69 countries, territories and the EU here
Oliver Patel, AIGP, CIPP/E has shared a wealth of information about AI legislation and his post about the recent AI summit in France is here
You don't need AI. You need impact. AI.IMPACT CTO I Consultant I Speaker
5 天前It is obvious, that AI will remain regulated locally. But it is still very good to work on frameworks that could be applied globally and are based on human rights and deep ethical thinking. The answers are not that obvious. Today, our toolset is entirely different than 5 years back. So there are no easy answers. But we have to try either way