AI Regulation 2026: EU vs US vs China
AI regulation is fragmented. Here's what founders need to know about the three major regulatory approaches.
The Three Approaches
🇪🇺 European Union
Philosophy: Privacy and fundamental rights first
- AI Act: Risk-based classification
- High risk: Strict requirements
- Low risk: Minimal obligations
- Global impact: Template for other regions
For founders: If you sell to Europe, comply with AI Act early
🇺🇸 United States
Philosophy: Innovation-first, industry self-regulation
- Executive orders: Guidelines, not laws
- State-level: Fragmented (California, Colorado)
- Sector-specific: FDA for healthcare AI
For founders: Follow NIST frameworks, expect state-level complexity
🇨🇳 China
Philosophy: State security and technological sovereignty
- Algorithmic recommendations: Transparency required
- Generative AI: Content moderation rules
- Data: Strict cross-border rules
For founders: Very different rules, often requires local partnership
Comparison Table
| Aspect | EU | US | China |
|---|---|---|---|
| Approach | Risk-based | Innovation-first | State control |
| Enforcement | Strong | Weak | Very strong |
| Scope | Broad | Narrower | Very broad |
| Penalty | Up to 6% revenue | Varies | Severe |
What This Means For Startups
If You're US-Based
- Focus on NIST AI Risk Management Framework
- Watch state laws (California, Colorado)
- Federal guidance is friendly to innovation
If You're Selling to Europe
- Prepare for AI Act compliance
- Document your AI systems
- Consider third-party audits
If You're Global
- Design for strictest (EU)
- Build compliance from day one
- Consider local partnerships for China
Key Trends
- Convergence: Some alignment emerging on high-risk AI
- Enforcement: EU leading, US catching up
- Standards: ISO/IEC developing global AI standards
Navigate AI policy with confidence. tldl summarizes podcasts from founders and investors building globally.