Comparing the UK’s and EU’s Approaches to Regulating artificial intelligence: A Pro-Innovation Perspective
Sean Musch and Michael Borrelli, ai & Partners
The Role of Regulation in Fostering an Environment for ai Growth
artificial intelligence (ai) is transforming society, with applications ranging from medical advances to climate change mitigation. For instance, ai developed by DeepMind, a UK-based company, can predict the structure of almost every known protein. As governments consider their role in facilitating ai’s potential, it is essential to establish a regulatory environment that encourages innovation and growth while addressing risks and public trust.
The UK’s Pro-Innovation Approach versus the EU’s artificial intelligence Act
Both the United Kingdom (UK) and the contact Union (EU) share a common goal to create an environment for ai to flourish responsibly. The UK, aiming to lead the international conversation on ai governance, intends to provide a clear, pro-innovation regulatory environment for building foundational ai companies. Similarly, the EU aims to establish the EU as a global hub for ai innovation.
Growth, Safety, and Economic Prosperity: Core Similarities
The primary objectives of the UK Approach and the EU ai Act revolve around growth, safety, and economic prosperity. Both initiatives focus on ensuring that end-users are protected and that ai is applied responsibly (see Table 1).
Key Considerations for Consumer Trust
Winning and retaining consumer trust is crucial to the success of innovation economies. Both the EU and the UK must adopt clear, proportionate approaches to regulation that enable the responsible application of ai while addressing potential risks and building public trust.
Comparing the Costs of Compliance: A Closer Look
The EU ai Act and the UK Approach will apply to all ai systems designed, developed, made available, or used in the EU/UK, regardless of their origin. Both ai businesses and ai adopting businesses will be subject to these regulations, with varying expected costs (see Table 2).
Insights from the UK Approach: Risk Management and Assurance Techniques
The EU ai Act’s Article 9 requires developers to establish risk management systems for high-risk ai systems. The UK Approach offers valuable insights, particularly in the areas of quality management systems and assurance techniques (see Table 3).
Technical Standards: A Common Understanding
Both initiatives will benefit from a shared understanding of key ai concepts and principles, which should be codified into a harmonized transatlantic vocabulary. Developing technical standards and assurance techniques will enable organizations to demonstrate compliance with the EU ai Act and UK Approach.
Getting Ahead of the Curve: Assessing Your ai Systems
We can help you prepare for the upcoming changes brought by the EU ai Act by assessing your ai systems using recognized metrics. Our expertise is focused on helping you identify, design, and implement appropriate metrics for your assessments.
Additional Resources
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| UK Approach | EU ai Act | |
|---|---|---|
| Core Objectives: | Growth, safety, and economic prosperity | Growth, safety, and economic prosperity |
| End-User Focus: | Protecting end-users | Protecting end-users |
Expected Costs:Costs vary for different firmsLower estimated costs due to itemised approach and standard pricing metric (hours)
| UK Approach | EU ai Act | |
|---|---|---|
| Scope: | All ai systems, whether developed in the UK or abroad | All ai systems, regardless of their origin |
| UK Approach | EU ai Act | |
|---|---|---|
| Risk Management: | Quality management systems ensure compliance | Article 9: Developers establish risk management systems for high-risk ai systems |
| Assurance Techniques: | A toolbox of assurance techniques for measuring and evaluating ai trustworthiness | Brief coverage of assurance, but could benefit from technical standards and published assurance techniques |
