In 2025, we witnessed a significant shift in the approach to AI regulation. The EU’s AI Act, considered the world’s first comprehensive AI-dedicated law, took effect, but instead of seeing a ‘Brussels effect’ on AI regulation, the global approach appears to be leaning towards that of the UK and U.S., which have led the charge for a looser regulatory environment in recent years.
## The EU Position
The EU’s AI Act has set a new standard for AI regulation, with key provisions taking effect in 2025. The rules require providers of general-purpose AI systems to comply with transparency and copyright obligations when placing their models on the EU market. As we look ahead to 2026, the bulk of the remaining AI Act provisions are scheduled to enter into force, targeting high-risk AI systems used in areas such as critical infrastructure, employment, and credit scoring.
However, the EU’s recently published Digital Omnibus Proposal has signaled a potential change in strategy, setting out intentions to streamline and make simplifications to a raft of existing digital and data legislation. While the Omnibus would not make substantive changes to the AI Act, it could provide a prolonged transition period for businesses by delaying the applicability of key provisions.
## The UK Position
The UK government’s proposal to lay a regulatory foundation for AI has been postponed, with the planned ‘AI Bill’ now expected in May 2026 at the earliest. Details remain limited, but the Bill is expected to operate as a framework and represents a less stringent and comprehensive approach when compared with the EU AI Act.
## The U.S. Position
In the U.S., a similar approach is being taken, with the White House demonstrating intent to slim down its digital legislative framework. The White House’s AI Action Plan and new Executive Order aim to ease federal oversight and establish a ‘minimally burdensome’ national framework on AI policy. However, with the scope of these plans still unclear and legal challenges unresolved, state laws are likely to endure, leaving U.S. companies to juggle federal guidance alongside a varied set of state requirements.
As we look to 2026, companies will need to stay agile, tracking evolving rules and preparing for a regulatory landscape that remains unpredictable. The EU’s AI Act has set a new standard for AI regulation, and businesses must navigate this fragmented landscape to ensure compliance and stay ahead of the curve.
With the EU’s AI Act taking effect in 2025 and the bulk of the remaining provisions scheduled to enter into force in 2026, companies must prepare for a more stringent regulatory environment. The EU’s Digital Omnibus Proposal could provide a prolonged transition period for businesses, but the ambiguity in this area remains. In 2026, companies will need to stay agile, tracking evolving rules and preparing for a regulatory landscape that remains unpredictable.
The UK and U.S. approaches to AI regulation are diverging from the EU’s more stringent stance, with the UK and U.S. aiming to provide technology companies with the freedom to innovate and develop in the market without the threat of stringent regulation. However, this approach may leave companies vulnerable to state-level rules and regulations, which could slow innovation.
In conclusion, the regulatory landscape for AI is becoming increasingly complex, with different approaches emerging across the globe. Companies must navigate this fragmented landscape to ensure compliance and stay ahead of the curve. By staying agile and tracking evolving rules, businesses can prepare for a regulatory landscape that remains unpredictable in 2026.
