UK vs US AI Regulation - Key Differences & Practical Compliance Issues

Introduction

AI regulation is developing along very different lines in the UK and US, creating particular challenges for lawyers advising clients operating across both jurisdictions. While neither has introduced a single comprehensive AI statute, the UK has adopted a principles-based approach, with existing regulators including the ICO, FCA, CMA and Ofcom applying cross-sector principles through their existing powers, supported by guidance, regulatory sandboxes and the Data (Use and Access) Act 2025.

The US has taken a more fragmented approach, with federal agencies such as the FTC, SEC, EEOC and CFPB applying existing laws to AI-related conduct alongside an increasingly complex patchwork of state legislation. At the same time, frameworks such as the NIST AI Risk Management Framework and ISO/IEC 42001 are increasingly influential in shaping expectations around responsible AI governance.

For lawyers advising businesses with AI products, suppliers, customers or operations spanning the UK and US, understanding these differences is becoming essential. This webinar will examine how the two approaches operate in practice, the key areas of divergence and the implications for compliance, contracting and risk management. It will also consider how businesses can develop a coherent AI governance framework that addresses requirements across multiple jurisdictions without creating unnecessary duplication.

The webinar will be particularly relevant to solicitors and in-house counsel advising on technology, data protection, commercial contracts, financial services or employment, as well as compliance professionals responsible for AI governance.

What You Will Learn

The webinar will cover the following:

• How the UK's principles-based approach operates in practice, including the roles of key regulators, their enforcement powers and where regulatory gaps remain
• Key UK developments, including the Data (Use and Access) Act 2025, automated decision-making, AI and copyright and developments around AI regulatory sandboxes
• How AI regulation is developing in the US through federal agency enforcement, including the FTC, SEC, EEOC and CFPB, with practical examples
• The emerging US state-law landscape, including developments in Colorado, Texas, California, Illinois and New York and the implications of potential federal pre-emption
• How NIST AI RMF, its Generative AI Profile, ISO/IEC 42001 and sector-specific frameworks are shaping expectations around AI governance
• The practical differences between the UK and US approaches to transparency, accountability, automated decision-making, liability and enforcement
• How to develop an AI governance framework capable of addressing UK, US and EU requirements without creating three separate compliance systems
• Key contractual considerations for AI procurement and supply, including warranties, audit rights and allocation of regulatory risk