Home / AI Regulation / Comparative Matrix

Comparative Matrix: AI Regulation Across Jurisdictions

A side-by-side view of how sixteen jurisdictions regulate AI, with an executive summary of the cross-jurisdiction picture. Snapshot as of 2026-10-10.

Executive summary

Two models, one direction of travel

Of the sixteen jurisdictions profiled here, only a minority have a binding AI-specific regime in force: the European Union (the AI Act as amended by the Digital Omnibus, Regulation (EU) 2026/1744, in force since 2026-07-27), South Korea (the AI Basic Act, in force since 2026-01-22, with a fines grace period reported to run to at least 2027-01-22) and, through departmental measures rather than a single statute, China. Germany has completed national implementation of the AI Act (KI-MIG, in force 2026-07-29). Most others are policy-led: Canada, Australia, Singapore and Japan rely on strategies, guidelines, sectoral rules and promotion-style statutes, while France, the Netherlands and Spain still have national implementing bills pending. A recurring lesson is that “issued” is not “effective”: the MAS guidelines and China’s “AI+” Opinion, for example, are in different stages of phase-in or are policy rather than rules.

Privacy and data-protection law is today’s enforcement lever

Where dedicated AI statutes are absent or not yet applicable, regulators are applying existing law. The Office of the Privacy Commissioner of Canada found complaints against OpenAI (#2026-002, 2026-05-06) and X Corp./xAI’s Grok (#2026-004, 2026-06-11) well-founded; the CNIL’s GDPR sanction of Uber (EUR 824,990,000, 2026-08-24; Dutch authority leading) targeted automated decision-making; Spain’s AEPD has issued AI guidance and surveillance warnings; Australia’s eSafety codes reach generative AI through online-safety law. Japan’s amended APPI and Korea’s PIPA reforms (effective 2027-03-09) are moving data law further toward AI use.

EU timeline

The Omnibus entered into force on 2026-07-27. Enforcement powers and Article 50 transparency duties apply from 2026-08-02; a new prohibition on non-consensual sexually explicit and child-abuse content (“nudification”) applies from 2026-12-02; high-risk obligations are deferred to 2027-12-02 (Annex III) and 2028-08-02 (Annex I). Penalty tiers remain EUR 35M/7%, EUR 15M/3% and EUR 7.5M/1%. Caveats: article-level text of Regulation 2026/1744 has not been checked against the Official Journal (EUR-Lex was unavailable during the research run); one genAI transparency sub-date is not reconciled across sources; and 2026-10-10 press reports of information requests to “30+” AI companies are reported but unconfirmed.

United States: federal posture, state substance

There is no comprehensive federal AI statute. Executive Order 14434 (signed 2026-09-29) is largely terminological, and EO 14365 (2025-12-11) sets a preemption posture backed by a DOJ AI Litigation Task Force, which intervened in xAI v. Weiser against Colorado. Binding duties sit in state law: Texas TRAIGA and California SB 53 have applied since 2026-01-01; Colorado repealed SB 24-205 and replaced it with SB 26-189 (effective 2027-01-01), with draft implementing rules open for comment to 2026-10-26. A reported FTC probe of leading AI developers (2026-09-30) is press-sourced and unverified.

Asia-Pacific and the Council of Europe

The region shows distinct models: China’s targeted, multi-regulator rules (including the Interim Measures for Anthropomorphic Interactive AI Services, in force 2026-07-15); Korea’s comprehensive Act with extraterritorial reach; Japan’s no-penalty promotion framework; Singapore’s voluntary frameworks plus MAS supervisory expectations for financial institutions (issued 2026-10-07, applying from 2027-10-07 and 2028-10-07); and Australia’s pivot from a proposed guardrails regime to mandatory “Australian Standards for AI” (frontier standards signalled for end-2026; legislation targeted for early 2027; the July 2026 Office of AI announcement lacks a primary source). The Council of Europe Framework Convention (CETS 225) is not in force: 21 signatories and one ratification (the EU, 2026-05-15) as of 2026-10-10; entry into force requires five ratifications including at least three Council of Europe member states, so it is not expected before 2027 at the current pace.

Snapshot as of 2026-10-10. Several statuses rely on secondary or press sources and are flagged unverified on the individual profiles. This is research assistance, not legal advice; verify against primary sources before reliance.