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Lab
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AI Governance and Regulation Β· Introduction

Who Governs the Machine That Governs Us?

Every powerful technology eventually meets the law β€” this course is about what happens when it does.

In 1844, Samuel Morse sent the first long-distance telegraph message from Washington to Baltimore, and within a decade the technology had outrun every existing legal framework governing communications, commerce, and privacy. Britain passed the Electric Telegraph Act in 1863 β€” nineteen years after the fact. The United States took until 1866. In the interim, stock traders in New York and London found ways to use the wire to front-run prices; newspapers published dispatches of uncertain provenance; and governments discovered, with considerable alarm, that a private company now controlled a nervous system they had not built and could not easily inspect.

That pattern β€” technology arrives, actors profit and sometimes harm, lawmakers scramble β€” is repeating with artificial intelligence, compressed into years rather than decades. The European Union adopted its AI Act in March 2024, the first comprehensive binding AI law anywhere in the world. The United States issued Executive Order 14110 on AI safety in October 2023, then partly rescinded it in January 2025. China published its Generative AI Measures in August 2023. Three major jurisdictions, three different theories of what the problem even is.

This course maps that contested terrain. It covers the EU AI Act's risk tiers, the US executive and legislative landscape, China's domestic approach, and the emerging international coordination bodies trying to prevent regulatory fragmentation. It will not tell you what the law will be in five years β€” no one can. What it will give you is the conceptual vocabulary and historical grounding to read new developments as they arrive and to reason about them with more precision than the headlines allow.

If you finish every module, here's who you become:

  • You'll understand the EU AI Act's risk-tier architecture and why the EU, US, and China each define the core problem differently.
  • You'll be able to read a new AI regulation or executive order and quickly locate its underlying theory of harm.
  • You'll trace the recurring pattern β€” technology outpaces law, actors profit, lawmakers scramble β€” and use it to anticipate where governance gaps are likely to appear next.
  • You'll know what industry self-regulation can and cannot credibly promise, and how to evaluate it against binding legal frameworks.
  • You'll become someone who brings conceptual precision to AI policy debates rather than recycling the assumptions embedded in headlines.
  • You'll be able to explain international coordination efforts like the EU-US Trade and Technology Council and articulate why regulatory fragmentation is itself a governance risk.
  • You'll leave with a durable vocabulary β€” risk tiers, jurisdictional divergence, self-regulatory gaps β€” that stays useful as the law keeps moving.
AI Governance and Regulation Β· Module 1 Β· Lesson 1

The EU AI Act: The World's First Binding AI Law

How Brussels built a risk-tiered framework and why every multinational is now reading it carefully.
What does it mean to regulate a technology by its risk level rather than its technical specifications?

On 21 April 2021, the European Commission released a 108-page proposal that would take three years to become law. Its architects β€” led by Commission Executive Vice-President Margrethe Vestager and Internal Market Commissioner Thierry Breton β€” deliberately avoided defining AI by its technical architecture. Instead, they asked a simpler question: what harm can this system cause, and to whom? The result was a four-tier risk pyramid that would reshape how companies worldwide design, document, and deploy AI systems.

The proposal triggered intense lobbying. Between 2021 and 2023, more than 600 organisations registered positions with the EU institutions on the AI Act β€” more than on the General Data Protection Regulation. The emergent complication was generative AI: ChatGPT launched in November 2022, mid-negotiation, and negotiators had to retrofit foundation-model rules into a framework that had not anticipated them. The final text, adopted by the European Parliament on 13 March 2024 by a vote of 523 to 46, ran to 459 articles.

The Four-Tier Risk Architecture

The EU AI Act organises AI systems into four risk categories, each carrying distinct obligations. Unacceptable risk systems are outright banned: social scoring by governments, real-time biometric surveillance in public spaces (with narrow law-enforcement exceptions), and AI that exploits psychological vulnerabilities. These provisions entered into force six months after the Act's publication, in February 2025.

High-risk systems β€” covering critical infrastructure, educational assessment, employment screening, credit scoring, biometric identification, and administration of justice β€” must satisfy conformity assessments before deployment, maintain technical documentation, ensure human oversight, and register in an EU database. Annex III of the Act lists eight categories of high-risk use cases that carry the heaviest pre-market obligations. A CV-screening tool used by a large employer, for example, falls into this category.

Limited-risk systems, principally chatbots and deepfake generators, face transparency requirements only: users must be informed they are interacting with AI. Minimal-risk systems β€” spam filters, AI in video games β€” face no mandatory requirements under the Act, though codes of practice may apply.

Key Development

The AI Act's biometric categorisation prohibition entered into force on 2 August 2026 for high-risk systems, but the ban on unacceptable-risk systems applied from 2 February 2025 β€” making it the earliest binding provision of the regulation to take effect.

General Purpose AI and the Foundation Model Rules

Title III of the final Act, added in response to the generative AI surge of 2022–2023, creates a distinct category: General Purpose AI (GPAI) models. Providers of GPAI models must maintain technical documentation, comply with EU copyright law, and publish summaries of training data. Models trained with more than 10^25 floating point operations β€” a threshold that currently captures GPT-4, Claude 3, and Gemini Ultra class systems β€” face additional systemic risk obligations including adversarial testing and incident reporting.

This distinction matters commercially. OpenAI, Google DeepMind, Anthropic, and Meta all fall within the GPAI rules' scope when deploying in the EU. The European AI Office, established in February 2024 within the Commission, serves as the designated supervisor for GPAI compliance β€” the first EU-level AI regulator with direct enforcement authority.

Enforcement and Penalties

Fines under the AI Act are calibrated to the tier of violation. Placing a prohibited AI system on the market can attract fines of up to €35 million or 7% of global annual turnover, whichever is higher. Violations of high-risk obligations carry up to €15 million or 3% of turnover. Supplying incorrect information to authorities carries up to €7.5 million or 1.5% of turnover.

The penalty structure is deliberately steeper than GDPR's maximum of 4% of turnover for the most severe violations β€” a signal that the EU regards certain AI harms as more serious than data protection breaches. Whether these penalties will be enforced at scale depends on national market surveillance authorities, whose capacity varies substantially across member states.

Conformity Assessment A pre-deployment evaluation process in which a high-risk AI system's developer (or a third-party notified body) verifies that the system meets the Act's technical and governance requirements before it can be placed on the EU market.
AI Office The European AI Office, established within the European Commission in February 2024, serves as the central EU supervisor for general purpose AI models and coordinator for national enforcement authorities.
Regulatory Sandbox A supervised testing environment that the AI Act requires member states to establish, allowing developers to test AI systems under real conditions with reduced regulatory burden in exchange for transparency obligations.
Practical Implication

Any company deploying AI in the EU β€” regardless of where it is headquartered β€” must comply with the AI Act. A US insurer using an algorithmic underwriting tool for EU customers is subject to its high-risk provisions. The Act's extraterritorial reach mirrors the GDPR's and is already shaping product decisions in Silicon Valley and Shenzhen.

Lesson 1 Quiz β€” The EU AI Act

Five questions Β· Select the best answer for each
1. The EU AI Act was adopted by the European Parliament on what date, and by what vote margin?
Correct. The Parliament adopted the final text on 13 March 2024 by a decisive 523–46 vote, after nearly three years of negotiation that began with the Commission's April 2021 proposal.
Not quite. The Parliament adopted the final text on 13 March 2024 by 523 votes to 46. The April 2021 date refers to the original Commission proposal, not the parliamentary vote.
2. Under the EU AI Act's risk pyramid, which category faces an outright ban rather than compliance obligations?
Correct. Unacceptable-risk systems β€” including government social scoring and real-time biometric surveillance in public spaces β€” are prohibited entirely. This ban took effect in February 2025.
Not correct. High-risk and limited-risk systems face compliance obligations, not bans. Unacceptable-risk systems are the category that is outright prohibited.
3. What computational threshold triggers the additional systemic-risk obligations for general purpose AI models under the Act?
Correct. The 10^25 FLOPs threshold was chosen to capture the frontier models that pose systemic risks β€” currently GPT-4, Claude 3, and Gemini Ultra class systems β€” while excluding smaller models.
Incorrect. The Act sets the threshold at 10^25 floating point operations, a figure calibrated to capture frontier-class systems like GPT-4 and Claude 3 while leaving smaller models outside the systemic-risk tier.
4. What is the maximum fine for placing a prohibited (unacceptable-risk) AI system on the EU market?
Correct. The €35 million / 7% ceiling for prohibited systems intentionally exceeds GDPR's 4% maximum, signalling that the EU treats certain AI harms as more serious than data protection violations.
Not correct. The ceiling for unacceptable-risk violations is €35 million or 7% of global annual turnover β€” deliberately steeper than GDPR's 4% maximum.
5. Which EU body was established in February 2024 to serve as the designated supervisor for general purpose AI model compliance?
Correct. The European AI Office was established within the European Commission in February 2024 β€” the first EU-level AI regulator with direct enforcement authority over GPAI models.
Incorrect. The body is the European AI Office, set up within the Commission in February 2024. The EDPB handles data protection, not AI system compliance.

Lab 1 β€” EU AI Act Risk Classification

Practice applying the Act's four-tier risk framework to real AI deployment scenarios

Your task

You will describe AI deployment scenarios and classify them under the EU AI Act's risk tiers. The lab assistant will challenge your reasoning, flag misclassifications, and explain edge cases β€” including how the same system can fall into different tiers depending on its deployment context.

Complete at least three substantive exchanges to finish this lab.

Try: "A hospital wants to use an AI tool to flag which emergency patients should be prioritised for treatment. What tier does this fall under and why?"
AI Act Classification Lab
EU AI Act Β· Risk Tiers
Welcome to the EU AI Act risk classification lab. Describe any AI system or deployment scenario and I'll walk you through how to classify it under the Act's four-tier framework β€” unacceptable, high, limited, or minimal risk. I'll also flag where the context of deployment, rather than the technology itself, drives the classification. What scenario would you like to work through?
AI Governance and Regulation Β· Module 1 Β· Lesson 2

The United States: Executive Orders, Congressional Deadlock, and Sectoral Rules

Why the US has regulated AI through executive action and agency guidance rather than legislation β€” and what that means for stability.
What happens when the world's leading AI developer nation lacks a unified federal AI law?

On 30 October 2023, President Biden signed Executive Order 14110 β€” "Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence" β€” the most comprehensive federal AI directive the United States had issued. It ran to 111 pages in the Federal Register, directed more than fifty federal agencies to take specific actions, and gave the National Institute of Standards and Technology ninety days to produce safety guidelines for frontier models. Fifteen months later, on 20 January 2025, the incoming Trump administration rescinded it on its first day in office. No replacement legislation had passed Congress.

That whipsaw captures the structural challenge of US AI governance: a constitutional system that gives the executive branch broad but reversible authority, a Congress that has been unable to pass major technology legislation since the Communications Decency Act of 1996, and a patchwork of sectoral regulators β€” the FTC, FDA, SEC, CFPB β€” each applying their existing statutory authority to AI in their domains without central coordination.

Executive Order 14110 and Its Provisions

EO 14110 contained several substantive requirements. Under the Defense Production Act, developers of frontier AI models β€” defined as those trained above a computational threshold of 10^26 operations β€” were required to report safety test results to the federal government before public deployment. The Order directed NIST to develop an AI Safety Institute (now renamed the AI Safety and Security Board under the Trump administration), and instructed the Department of Homeland Security to assess AI risks to critical infrastructure.

The Order also required federal agencies to designate a Chief AI Officer and produce inventories of their AI use cases. By the end of 2024, agencies had filed more than 1,700 AI use-case entries in the federal AI use-case inventory β€” the first systematic accounting of AI deployment across the executive branch.

Congressional Activity: COMPETES, CHIPS, and the Legislative Gap

Congress has not passed a comprehensive AI governance statute. The CHIPS and Science Act of 2022 allocated $52.9 billion to semiconductor manufacturing and $200 billion for scientific research, including AI β€” a competitiveness measure rather than a governance one. The National AI Initiative Act of 2020 established coordination mechanisms among federal AI research programs but imposed no restrictions on private actors.

Multiple bills have been introduced. The Algorithmic Accountability Act has been reintroduced in successive Congresses since 2019 without passage. The AI Foundation Model Transparency Act, introduced in 2023, would require model cards and training data disclosures for large models; it has not advanced beyond committee. The Senate's bipartisan AI roadmap, published in May 2024, called for $32 billion in AI investment and sector-specific regulation β€” but produced no legislation before the 118th Congress ended.

State-Level Activity

In the absence of federal legislation, states have moved. California's AB 2013 (2024) requires disclosure of training data for generative AI. Colorado's SB 205 (2024) creates consumer protections against algorithmic discrimination in high-stakes decisions. Illinois's BIPA (Biometric Information Privacy Act, 2008) has been used in hundreds of AI-related lawsuits. Texas's CAPAI Act, enacted in 2025, applies risk-management requirements to high-risk AI systems β€” closely mirroring the EU framework.

Sectoral Regulation: The FTC, FDA, and CFPB Approaches

The Federal Trade Commission has applied its Section 5 unfair or deceptive practices authority to AI. In January 2023, the FTC published guidelines warning that AI-generated endorsements and synthetic reviews violate existing law. In September 2024, the FTC settled with DoNotPay β€” a company marketing AI legal services β€” for making unsubstantiated claims about its AI's capabilities, the first such action against a consumer AI product.

The Food and Drug Administration has a more structured approach: it has cleared more than 950 AI/ML-enabled medical devices as of 2024, applying its existing 510(k) and De Novo pathways. In April 2023, FDA published a framework for marketing submissions of AI/ML-based software as a medical device, establishing how manufacturers can propose predetermined change control plans β€” allowing models to update post-clearance within defined bounds.

The Consumer Financial Protection Bureau, in a 2022 circular, confirmed that the Equal Credit Opportunity Act requires lenders to give specific reasons for adverse credit decisions even when those decisions are made by algorithmic models β€” a significant constraint on black-box underwriting in the US mortgage and credit markets.

Executive Order A directive issued by the US President under constitutional or statutory authority, binding on federal agencies but rescindable by any subsequent president and not equivalent to legislation.
Section 5 FTC Authority The Federal Trade Commission Act's prohibition on "unfair or deceptive acts or practices," which the FTC has applied to AI-generated content, algorithmic pricing, and misleading AI capability claims without new AI-specific legislation.
Structural Comparison

The EU AI Act is a horizontal regulation applying across all sectors. US AI regulation is vertical β€” each sector applies its own existing rules, with the result that a healthcare AI faces FDA scrutiny, a financial AI faces CFPB rules, and a hiring AI faces EEOC guidance, with no single framework unifying them. Both approaches have defenders. Sectoral regulation allows expertise; horizontal regulation allows consistency.

Lesson 2 Quiz β€” US AI Governance

Five questions Β· Select the best answer for each
1. Executive Order 14110 on AI was signed in October 2023 and rescinded in January 2025. What statute did it invoke to require frontier model developers to report safety results to the government?
Correct. EO 14110 invoked the Defense Production Act to compel frontier AI developers β€” those training above 10^26 operations β€” to share safety test results with the federal government before public release.
Incorrect. EO 14110 used the Defense Production Act for this requirement. The Communications Decency Act (1996) governs online liability, not AI safety reporting.
2. What was the primary purpose of the CHIPS and Science Act of 2022?
Correct. The CHIPS Act allocated $52.9 billion to semiconductor manufacturing and $200 billion for scientific research β€” a competitiveness and investment measure, not a governance or restriction framework.
Incorrect. The CHIPS and Science Act was primarily a competitiveness measure funding semiconductor manufacturing ($52.9 billion) and scientific research ($200 billion), not an AI governance statute.
3. In September 2024, the FTC settled against DoNotPay. What was the basis of the action?
Correct. DoNotPay claimed its AI could perform as well as a human lawyer across a range of legal services. The FTC found these claims unsubstantiated under Section 5 β€” the first such enforcement action against a consumer AI product.
Not correct. The FTC's action was under Section 5 for deceptive practices β€” specifically, DoNotPay's unsubstantiated marketing claims about the capabilities of its AI legal service assistant.
4. Which US state passed the BIPA statute, first enacted in 2008, which has since been used in hundreds of AI-related lawsuits?
Correct. Illinois's Biometric Information Privacy Act (BIPA), enacted in 2008, predates the modern AI era but has become a major vehicle for AI-related litigation, particularly around facial recognition and biometric data processing.
Incorrect. BIPA is an Illinois law, enacted in 2008. It has been particularly important for facial recognition litigation and has influenced subsequent biometric privacy laws in other states.
5. What key constraint did the CFPB's 2022 circular place on algorithmic credit decisions in the United States?
Correct. The CFPB circular confirmed that the Equal Credit Opportunity Act's adverse action notice requirements apply to algorithmic models β€” lenders cannot deny credit citing an opaque model without specifying the reasons.
Not correct. The CFPB circular applied the Equal Credit Opportunity Act's existing adverse action requirement to algorithmic decisions β€” lenders must give specific reasons for algorithmic denials, not merely cite a model score.

Lab 2 β€” US Regulatory Jurisdiction Mapping

Identify which US federal regulator governs a given AI deployment scenario

Your task

The US has no single AI regulator. For each scenario you describe, identify which federal agency or statute applies β€” FTC, FDA, CFPB, EEOC, SEC, or another body β€” and explain the legal hook. The assistant will assess your mapping and introduce complications such as overlapping jurisdiction or regulatory gaps.

Complete at least three substantive exchanges to finish this lab.

Try: "A financial services firm uses a large language model to generate personalised investment advice for retail clients. Which US regulators would have jurisdiction and under what authority?"
US Regulatory Mapping Lab
US AI Governance Β· Sectoral
Welcome to the US regulatory jurisdiction lab. The United States regulates AI vertically through sector-specific agencies rather than through a single horizontal statute. Describe an AI deployment scenario and I'll help you map which federal regulator has jurisdiction, what statutory authority they are using, and where the gaps or overlaps lie. What scenario would you like to analyse?
AI Governance and Regulation Β· Module 1 Β· Lesson 3

China's AI Governance: State-Directed Development Under Algorithmic Control

How Beijing regulates AI through a sequence of targeted rules rather than a single omnibus law β€” and what that reveals about different theories of governance.
Can a country simultaneously be the world's most prolific AI regulator and one of the most aggressive AI deployers?

When the Cyberspace Administration of China published its Interim Measures for the Management of Generative Artificial Intelligence Services on 13 July 2023 β€” effective 15 August β€” it became the first major jurisdiction to impose binding rules specifically on generative AI. The measures arrived eight months before the EU AI Act's parliamentary vote, and months before any comparable US federal action. They required providers to submit security assessments before launch, label AI-generated content, and ensure outputs "embody core socialist values" β€” a requirement with no counterpart in Western frameworks and one that drew immediate attention from companies seeking to operate in the Chinese market.

This was not China's first AI regulation. It was the third in a sequence that had begun in 2021. Each rule addressed a specific technology or risk: recommendation algorithms in 2021, deepfakes in 2022, generative AI in 2023. The approach was deliberate β€” targeted rules issued quickly, tested against deployment realities, then revised β€” rather than the years-long horizontal rulemaking the EU undertook. The tradeoff was coherence: by 2024, China had four overlapping AI regulatory instruments with no single coordinating statute.

China's Layered AI Regulatory Architecture (2021–2024)

China's AI governance rests on a series of regulations issued by the Cyberspace Administration of China (CAC), sometimes in coordination with the National Development and Reform Commission and the Ministry of Industry and Information Technology. The four principal instruments are:

Provisions on the Management of Algorithmic Recommendations (effective March 2022) β€” Applied to recommendation systems on platforms like Douyin (TikTok's Chinese version), Weibo, and Baidu. Providers must label algorithmically recommended content, allow users to opt out of profiling, and avoid using algorithms to engage in "improper commercial marketing" or induce addiction in minors.

Provisions on the Management of Deep Synthesis Technology (effective January 2023) β€” Targeted synthetic media, requiring watermarking of AI-generated content and prohibiting deepfakes that "endanger national security" or spread disinformation. This is the Chinese provision closest in spirit to the EU AI Act's transparency requirements for limited-risk systems.

Interim Measures for Generative AI Services (effective August 2023) β€” Required pre-launch security assessments for generative AI services available to the Chinese public, prohibited outputs contradicting "socialist core values," and mandated that providers verify user identity and maintain logs of prompts and outputs for six months.

Draft AI Law (circulated 2024) β€” China has been drafting a more comprehensive AI law since at least 2023. A draft circulated in 2024 contemplates a risk classification system with some similarities to the EU framework, though with distinct provisions for national security and state-directed AI development.

The Security Assessment Requirement

Under the Generative AI Measures, any service provider offering generative AI to Chinese users must complete a security assessment filed with the CAC before launch. By the end of 2023, the CAC had approved more than a dozen models β€” including Baidu's Ernie Bot, Alibaba's Tongyi Qianwen, and iFlytek's Spark. Foreign providers face a structural obstacle: the assessment requires disclosing model architecture and training methodology to Chinese regulators, a disclosure most Western providers are unwilling to make.

State Promotion and Regulatory Tension

China's AI governance operates within a different political economy than either the EU or US frameworks. The government is simultaneously a regulator, a major funder, and in some cases a direct customer of AI systems. The New Generation AI Development Plan (2017) set targets for China to become the world leader in AI by 2030, with state investment targets of 1 trillion yuan by that date.

This dual role creates tension. Stringent pre-launch assessments can slow the domestic AI industry that the state is trying to advance. The CAC has handled this by applying the security assessment requirement primarily to consumer-facing services, leaving enterprise and government-procurement AI deployments under lighter-touch review. The result is a regulatory architecture that constrains foreign access and shapes public-facing AI content while preserving operational space for domestic industrial deployment.

Extraterritorial Dimensions: The TikTok Case

The intersection of Chinese AI governance and Western regulatory concern crystallised in the 2023–2024 legislative process around TikTok. In April 2024, the US Congress passed the Protecting Americans from Foreign Adversary Controlled Applications Act, giving ByteDance 270 days to divest TikTok or face a US operating ban. The Supreme Court upheld the statute in January 2025.

The TikTok case illustrates how AI governance is becoming entangled with national security architecture. TikTok's recommendation algorithm β€” technically a high-precision content-ranking AI β€” was the proximate concern. Congressional testimony focused not on algorithmic harm in the conventional sense but on data flows, potential for content manipulation, and the applicability of Chinese law (including the 2017 National Intelligence Law) to ByteDance's data assets.

Cyberspace Administration of China (CAC) China's primary internet and AI regulator, responsible for issuing and enforcing the algorithmic recommendation, deep synthesis, and generative AI measures. The CAC reports to the State Council and operates with both legislative and enforcement authority.
Socialist Core Values Requirement A provision in China's Generative AI Measures requiring that AI outputs not contradict the officially defined "socialist core values" β€” a substantive content constraint with no equivalent in EU or US AI regulation.
Regulatory Divergence

China's approach to AI governance β€” rapid targeted rules, state promotion alongside regulation, content constraints tied to political values β€” diverges fundamentally from both the EU's rights-based horizontal framework and the US's market-oriented sectoral approach. Companies operating globally must navigate all three simultaneously, and the requirements are sometimes mutually incompatible.

Lesson 3 Quiz β€” China's AI Governance

Five questions Β· Select the best answer for each
1. China's Interim Measures for Generative AI Services took effect in August 2023. Which government body issued them?
Correct. The CAC is China's primary AI and internet regulator, responsible for all three major AI-specific regulatory instruments issued between 2022 and 2023.
Not correct. All three AI-specific instruments β€” algorithmic recommendations, deep synthesis, and generative AI β€” were issued by the Cyberspace Administration of China (CAC).
2. How long are generative AI service providers in China required to retain logs of user prompts and outputs under the 2023 Measures?
Correct. The 2023 Interim Measures require providers to maintain logs of prompts and outputs for six months β€” a provision that has significant implications for user privacy and for the practical ability of foreign providers to operate in China.
Incorrect. The Generative AI Measures require a six-month retention period for prompt and output logs, creating substantial data storage and privacy obligations for service providers.
3. The Provisions on the Management of Deep Synthesis Technology, effective January 2023, are most analogous to which part of the EU AI Act?
Correct. China's deep synthesis provisions require content watermarking and labelling β€” a transparency obligation most similar to the EU's limited-risk tier, which requires that AI-generated content be disclosed to users.
Incorrect. The deep synthesis rules focus on transparency and labelling of synthetic content β€” most analogous to the EU's limited-risk tier obligations, not the high-risk conformity assessment or GPAI systemic-risk tiers.
4. What structural obstacle prevents most Western AI providers from completing China's pre-launch security assessment?
Correct. The CAC security assessment requires detailed disclosure of model architecture and training data β€” information most Western providers regard as core intellectual property and are unwilling to share with a foreign government regulator.
Not correct. The principal barrier is that the security assessment requires Western providers to disclose proprietary model architecture and training methodology to the CAC, a disclosure most are unwilling to make.
5. In what year did the US Congress pass legislation giving ByteDance a deadline to divest TikTok or face a US operating ban?
Correct. The Protecting Americans from Foreign Adversary Controlled Applications Act passed in April 2024, and the Supreme Court upheld it in January 2025 β€” the first US statute to target a specific AI-driven platform on national security grounds.
Incorrect. Congress passed the divestiture legislation in April 2024. The Supreme Court upheld it in January 2025, after which TikTok briefly went dark in the US before being permitted to continue operating pending a divestiture process.

Lab 3 β€” Comparative Regulatory Analysis

Compare how the EU, US, and China frameworks treat the same AI deployment scenario

Your task

Regulatory arbitrage β€” deploying AI in whichever jurisdiction imposes the fewest constraints β€” is a real phenomenon. In this lab, describe an AI product or system and analyse how it would be treated under all three frameworks simultaneously. The assistant will help you identify conflicts, gaps, and genuine compliance challenges for multinational operators.

Complete at least three substantive exchanges to finish this lab.

Try: "A social media platform uses AI to rank content feeds for users in the EU, US, and China. What are the key obligations and conflicts across all three frameworks?"
Comparative Regulatory Lab
EU Β· US Β· China Β· Multi-Jurisdiction
Welcome to the comparative regulatory analysis lab. The EU AI Act, US sectoral framework, and China's CAC-led measures represent three genuinely different theories of AI governance. A product that is fully compliant in one jurisdiction may face serious obstacles in another. Describe an AI system and I'll walk you through the obligations, conflicts, and practical challenges of operating it across all three jurisdictions simultaneously. What system would you like to analyse?
AI Governance and Regulation Β· Module 1 Β· Lesson 4

International Coordination: The AI Safety Summit, OECD Principles, and the Race to Set Global Standards

Why nations that disagree on AI governance nonetheless keep meeting β€” and what the emerging international architecture actually accomplishes.
When states cannot agree on rules, what does international coordination actually achieve?

On 1–2 November 2023, representatives from 28 countries β€” including the United States, China, the European Union, and the United Kingdom β€” gathered at Bletchley Park, the Second World War codebreaking site, for the first AI Safety Summit. The choice of venue was deliberate: Bletchley's wartime history of technical ingenuity deployed under existential pressure was the intended frame. The summit produced the Bletchley Declaration, signed by all 28 participating governments, acknowledging that "frontier AI" poses potentially catastrophic risks and committing to a shared process of safety evaluation. It was the first time China and the United States had co-signed a joint AI governance document.

The Declaration contained no binding obligations. Critics noted that agreeing risks exist is not the same as agreeing what to do about them. Supporters argued that the mere fact of joint acknowledgement by geopolitical rivals represented meaningful progress. A second summit followed in Seoul in May 2024, producing the Seoul Ministerial Statement and a commitment to establish international AI Safety Institutes that would coordinate on model evaluations. A third summit was held in Paris in February 2025, where the AI Action Summit focused more heavily on applications and economic opportunity than on frontier risk.

The OECD AI Principles: The Baseline Framework

Before the summit process, the most established international AI governance framework was the OECD AI Principles, adopted in May 2019 and revised in 2024. The principles were the first intergovernmental standard on AI, endorsed by all 38 OECD members and subsequently adopted by G20 leaders. They identify five values-based principles: inclusive growth and sustainable development; human-centred values and fairness; transparency and explainability; robustness, security, and safety; and accountability.

The OECD Principles are non-binding. They serve as a normative reference point that many national frameworks explicitly cite β€” the EU AI Act, the US NIST AI Risk Management Framework, and Canada's Directive on Automated Decision-Making all reference or align with OECD terminology. This soft-law anchoring function is their primary practical value: by establishing shared vocabulary, they reduce the cost of mutual recognition between different national regimes.

The NIST AI Risk Management Framework

In January 2023, the US National Institute of Standards and Technology released the AI Risk Management Framework (AI RMF 1.0). Unlike a regulation, the RMF is a voluntary guidance document β€” but it has been widely adopted. EO 14110 directed federal agencies to align their AI procurement and deployment practices with it; multiple Fortune 500 companies have publicly aligned their AI governance programs to it; and NIST has developed sector-specific profiles for healthcare AI and generative AI (Generative AI Profile, published July 2024).

The RMF organises AI risk management into four functions: Govern, Map, Measure, and Manage. The Govern function addresses accountability structures and organisational culture. Map involves identifying AI risks in context. Measure involves evaluating those risks quantitatively or qualitatively. Manage involves responding to assessed risks through mitigation, transfer, or acceptance. The framework's influence on corporate AI governance programs globally has been substantial, even in jurisdictions not subject to US law.

The G7 Hiroshima AI Process

At the G7 summit in Hiroshima in May 2023, leaders launched the Hiroshima AI Process, which produced the International Guiding Principles on AI and a voluntary Code of Conduct for AI developers in October 2023. The Code of Conduct was endorsed by eleven leading AI companies including OpenAI, Google DeepMind, Microsoft, and Anthropic. It covers transparency, incident reporting, information sharing with governments, and red-team testing for frontier models β€” a set of commitments stronger in specificity than the Bletchley Declaration but still entirely voluntary.

The AI Safety Institute Network

One concrete outcome of the Bletchley and Seoul summits is the emergence of national AI Safety Institutes (AISIs). The UK established the world's first AISI in November 2023; the US followed with its own in February 2024 (subsequently renamed the AI Safety and Security Board). By mid-2024, Japan, Singapore, Canada, France, and South Korea had announced equivalent bodies. At the Seoul summit, these institutes signed an agreement to cooperate on model evaluations β€” sharing methodologies and coordinating on which frontier models receive safety testing.

The network represents a pragmatic approach to international coordination: rather than treaty-level harmonisation of regulations, which faces serious political obstacles, states agree on shared technical evaluation standards. If the major AI jurisdictions accept common benchmarks for what constitutes a "safe" frontier model, regulatory requirements may converge in practice even without formal legal harmonisation.

The Standards Gap: ISO/IEC and IEEE

Below the governmental level, technical standards bodies are producing specifications that will underpin regulatory compliance. ISO and IEC are jointly developing the ISO/IEC 42001 standard for AI management systems β€” published in December 2023, it is the first international management system standard specifically for AI. IEEE has published over 25 AI ethics standards including IEEE 7000 (addressing ethical concerns during system design), IEEE 7001 (transparency of autonomous systems), and IEEE 7010 (wellbeing metrics for autonomous systems).

The EU AI Act explicitly references harmonised standards as a compliance pathway for high-risk systems: a manufacturer whose product conforms to relevant EU harmonised standards is presumed to meet the Act's requirements. The European Committee for Standardisation (CEN/CENELEC) was mandated to develop these standards in 2023; the first tranche was expected by 2025. How quickly ISO/IEC 42001 is designated as a harmonised standard under the AI Act will determine how much of compliance becomes a certification exercise rather than a bespoke legal assessment.

Bletchley Declaration A joint statement signed by 28 governments in November 2023 acknowledging the potential catastrophic risks of frontier AI and committing to a shared international safety evaluation process β€” the first AI governance document co-signed by both the US and China.
ISO/IEC 42001 The first international management system standard specifically for AI, published December 2023, providing organisations with a framework for establishing, implementing, and improving AI governance systems β€” a potential compliance pathway under the EU AI Act.
NIST AI RMF The US National Institute of Standards and Technology's voluntary AI Risk Management Framework (released January 2023), organising AI risk governance into four functions: Govern, Map, Measure, and Manage.
The Emerging Architecture

International AI governance is converging on a layered architecture: non-binding intergovernmental principles (OECD, G7) provide normative vocabulary; national regulations (EU AI Act, China Measures) provide binding rules; voluntary frameworks (NIST RMF, G7 Code of Conduct) provide operational guidance; and technical standards (ISO/IEC 42001) provide certification pathways. The layers interact but do not yet form a coherent system. Understanding where each instrument sits β€” and where the gaps remain β€” is the central practical competency in AI governance work.

Lesson 4 Quiz β€” International AI Governance

Five questions Β· Select the best answer for each
1. The first AI Safety Summit was held at Bletchley Park in November 2023. How many governments signed the Bletchley Declaration?
Correct. Twenty-eight governments, including the US, China, and EU member states, signed the Bletchley Declaration β€” making it the first AI governance document co-signed by both the US and China.
Incorrect. Twenty-eight governments signed the Bletchley Declaration in November 2023. The significance was that both the US and China were among the signatories.
2. The OECD AI Principles were first adopted in what year and later revised in what year?
Correct. The OECD AI Principles were adopted in May 2019 β€” the first intergovernmental AI standard β€” and revised in 2024 to reflect developments in foundation models and generative AI.
Not correct. The OECD AI Principles were first adopted in May 2019, making them the first intergovernmental AI governance standard. They were revised in 2024.
3. The NIST AI Risk Management Framework (RMF 1.0) organises AI risk management into four functions. Which of the following is NOT one of those four functions?
Correct. The NIST AI RMF's four functions are Govern, Map, Measure, and Manage. "Audit" is not one of them, though auditing activities may occur within the Measure function.
Incorrect. "Audit" is not one of the four NIST AI RMF functions. The framework uses: Govern (organisational accountability), Map (risk identification), Measure (risk evaluation), and Manage (risk response).
4. ISO/IEC 42001, published in December 2023, is significant because it is the first international standard to do what?
Correct. ISO/IEC 42001 is the first international management system standard specifically for AI β€” analogous to ISO 9001 for quality management or ISO 27001 for information security, but applied to AI governance systems.
Incorrect. ISO/IEC 42001 provides a management system framework for AI governance β€” the first of its kind. It does not set safety thresholds or create mandatory certification, though it may become a harmonised standard under the EU AI Act.
5. At the G7 Hiroshima AI Process in October 2023, approximately how many leading AI companies endorsed the voluntary Code of Conduct?
Correct. Eleven AI companies including OpenAI, Google DeepMind, Microsoft, and Anthropic endorsed the G7 Code of Conduct in October 2023, committing to transparency, incident reporting, and red-team testing of frontier models.
Incorrect. Eleven companies endorsed the Hiroshima AI Process Code of Conduct, including OpenAI, Google DeepMind, Microsoft, and Anthropic. While voluntary, the commitments were more specific than the Bletchley Declaration.

Lab 4 β€” International Standards and Governance Gaps

Analyse where existing international AI governance frameworks succeed and where they fall short

Your task

International AI governance relies heavily on voluntary instruments, soft law, and technical standards. In this lab, you will explore specific governance scenarios β€” including areas where no binding international rule exists β€” and assess what the existing toolkit (OECD Principles, NIST RMF, ISO/IEC 42001, AI Safety Institute network) can and cannot accomplish.

Complete at least three substantive exchanges to finish this lab.

Try: "An AI system used for autonomous weapons targeting is developed by a country that is not party to any AI governance agreement. What international legal tools exist to address this, and where do they fall short?"
International Governance Lab
OECD Β· NIST Β· ISO Β· Bletchley
Welcome to the international AI governance lab. The global AI governance landscape is a patchwork of non-binding principles, voluntary codes, national regulations with extraterritorial reach, and emerging technical standards β€” with significant gaps at the international level. Bring me a scenario and I'll help you identify what tools exist, what they can actually accomplish, and where the genuine gaps in coverage lie. What would you like to explore?

Module 1 Test β€” Global AI Policy Landscape

15 questions Β· Score 80% or above to pass Β· All four lessons covered
1. What is the correct chronological order of these EU AI Act milestones?
Correct. The proposal came first in April 2021, the AI Office was established in February 2024 during final negotiations, and the Parliament voted in March 2024.
Incorrect. The correct order is: Commission proposal (April 2021) β†’ European AI Office established (February 2024) β†’ Parliamentary vote (March 2024).
2. A CV-screening algorithm used by an EU-based employer to filter job applicants falls under which EU AI Act risk tier?
Correct. Annex III of the AI Act explicitly lists AI used in employment, worker management, and access to self-employment as a high-risk category, requiring conformity assessment before deployment.
Not correct. Employment screening AI falls in Annex III as a high-risk use case β€” requiring conformity assessment, technical documentation, human oversight, and EU database registration.
3. The EU AI Act's unacceptable-risk ban provisions entered into force in which month and year?
Correct. The unacceptable-risk prohibitions applied from 2 February 2025 β€” six months after the Act's publication β€” making them the first binding provisions of the AI Act to take effect.
Incorrect. The unacceptable-risk ban took effect on 2 February 2025, six months after the Act's official publication. High-risk system requirements have a longer implementation timeline.
4. Which US statute, predating the AI era, has been cited as the primary legal basis for the FTC's enforcement actions against AI companies making deceptive capability claims?
Correct. Section 5 of the FTC Act β€” prohibiting unfair or deceptive acts or practices β€” is the FTC's primary tool for AI enforcement, applied to false capability claims, synthetic endorsements, and misleading AI marketing.
Incorrect. The FTC applies Section 5 of the FTC Act β€” its longstanding consumer protection authority β€” to AI-related deceptions without requiring new AI-specific legislation.
5. How many AI/ML-enabled medical devices had the FDA cleared in the United States as of 2024?
Correct. The FDA had cleared more than 950 AI/ML-enabled medical devices by 2024, making it by volume the most active US regulator in the AI product space, applying existing 510(k) and De Novo pathways.
Incorrect. As of 2024, the FDA had cleared more than 950 AI/ML-enabled medical devices β€” by volume, one of the most significant AI regulatory records of any US agency.
6. China's 2022 Provisions on Algorithmic Recommendations applied most directly to which type of platform?
Correct. The 2022 Provisions targeted recommendation algorithms on content platforms β€” Douyin (TikTok's Chinese version), Weibo, Baidu β€” requiring labelling of recommended content and opt-out mechanisms.
Not correct. The 2022 Algorithmic Recommendations Provisions were aimed at content-ranking algorithms on social and news platforms, not generative AI models or autonomous systems.
7. Which of the following statements about the EU AI Act's extraterritorial reach is accurate?
Correct. Like the GDPR, the EU AI Act has extraterritorial application β€” any company, anywhere in the world, deploying AI systems affecting EU users is subject to its requirements.
Incorrect. The EU AI Act mirrors the GDPR's extraterritorial scope β€” it applies to any organisation deploying AI affecting EU users, regardless of the organisation's location, size, or server geography.
8. The Bletchley Declaration (November 2023) is distinguished from earlier AI governance statements primarily because:
Correct. The Bletchley Declaration's political significance was that it secured joint acknowledgement of AI risks from geopolitical rivals β€” most notably the simultaneous participation of the US and China.
Not correct. The Bletchley Declaration's distinctive significance was geopolitical: it was the first AI governance document co-signed by both the US and China. It contained no binding obligations.
9. Under China's Generative AI Measures, which domestic models had received CAC security assessment approval by end of 2023?
Correct. By end of 2023 the CAC had approved more than a dozen models, including Baidu's Ernie Bot, Alibaba's Tongyi Qianwen, and iFlytek's Spark. Foreign providers faced structural obstacles to completing the same assessment.
Incorrect. Among the approved models were Baidu's Ernie Bot, Alibaba's Tongyi Qianwen, and iFlytek's Spark. Foreign providers like OpenAI have not obtained CAC approval due to the model disclosure requirement.
10. The US National AI Initiative Act of 2020 primarily did which of the following?
Correct. The National AI Initiative Act created coordination structures for federal AI R&D β€” a research investment and coordination measure, not an AI governance or restriction statute.
Not correct. The National AI Initiative Act of 2020 established coordination mechanisms among federal AI research programs. The NIST AI RMF came later, in January 2023.
11. The AI Safety Institute network formed after Bletchley and Seoul agreed to cooperate primarily on which activity?
Correct. The AISI network signed a cooperation agreement at Seoul focused on shared evaluation methodologies β€” a technical coordination approach rather than regulatory harmonisation.
Incorrect. The AI Safety Institute network's cooperation agreement focused on shared methodologies for frontier model safety evaluations, not liability law harmonisation or export controls.
12. What makes the OECD AI Principles' primary practical value as an international governance instrument?
Correct. As non-binding soft law, the OECD Principles' primary function is normative anchoring β€” giving different national frameworks a common vocabulary, which facilitates mutual recognition and reduces compliance friction.
Not correct. The OECD Principles are non-binding. Their primary value is establishing shared vocabulary and normative reference points that make it easier for different national frameworks to recognise each other's approaches.
13. Colorado's SB 205, enacted in 2024, is significant in the US state AI governance landscape because it:
Correct. Colorado SB 205 (2024) focused on consumer protection against algorithmic discrimination, particularly in insurance and lending decisions β€” one of the more substantive US state AI governance statutes enacted in 2024.
Not correct. Colorado SB 205 created consumer protections against algorithmic discrimination in high-stakes decisions such as insurance and credit β€” an approach that mirrors aspects of EU high-risk AI obligations.
14. Which of the following correctly describes the key difference between the EU's horizontal AI regulation and the US's vertical/sectoral approach?
Correct. This is the fundamental structural distinction β€” the EU AI Act is one law covering all sectors, while US AI governance operates through the FTC, FDA, CFPB, EEOC, SEC and other regulators each applying their own existing statutory authority.
Incorrect. The core distinction is scope: the EU uses a single horizontal regulation across all sectors, while the US uses sector-specific agencies (FTC, FDA, CFPB, SEC, EEOC) each applying their existing authority to AI in their domain.
15. ISO/IEC 42001 is potentially significant for EU AI Act compliance because:
Correct. Under EU harmonised standards law, a product conforming to a designated harmonised standard is presumed to meet the corresponding regulatory requirements β€” making ISO/IEC 42001 designation a potential certification shortcut for AI Act compliance.
Incorrect. If CEN/CENELEC designates ISO/IEC 42001 as an EU harmonised standard, manufacturers whose AI management systems conform to it would benefit from a presumption of conformity with corresponding EU AI Act requirements β€” a significant compliance pathway.