TL;DR
- EU: The AI Act and GDPR focus on transparency, data protection, and risk classification.
- U.S.: The Algorithmic Accountability Act and the FTC enforce fairness and accountability in AI systems.
- China: Prioritises state control, data security, and social responsibility.
- Japan: Takes a collaborative approach with voluntary AI Utilization Guidelines.
- Kleritt helps SMBs implement AI solutions that meet international compliance standards.
European Union
The AI Act
The EU AI Act is the world’s first comprehensive law focused entirely on artificial intelligence. It classifies AI systems based on their potential risk to society:
- Unacceptable risk: AI uses that are banned (e.g. social scoring or manipulative behaviour prediction).
- High risk: Systems in healthcare, employment, or law enforcement that must meet strict transparency and safety requirements.
- Limited risk: AI must disclose that users are interacting with an AI (e.g. chatbots).
- Minimal risk: Most general AI tools can operate freely, with ethical guidelines encouraged.
Companies using AI in the EU must follow documentation, testing, and human oversight requirements. The Act also mandates risk assessments before deployment and clear instructions for end users.
GDPR (General Data Protection Regulation)
The GDPR remains central to AI governance in Europe. It protects personal data and ensures individuals have control over how their information is used.
For AI, this means:
- Data collection must have a clear purpose and legal basis.
- Users must give explicit consent for data-driven AI systems.
- Fully automated decisions that impact individuals require human review.
- Businesses must explain how algorithms make decisions (the right to explanation).
In practice, GDPR and the AI Act complement each other: GDPR governs data use, while the AI Act governs system behaviour.
United States
Algorithmic Accountability Act
The Algorithmic Accountability Act (proposed in the U.S. Congress) requires companies to perform impact assessments for AI systems that make automated decisions about people, such as hiring, credit approval, or insurance.
Key goals:
- Prevent algorithmic discrimination and bias.
- Ensure transparency about how models work and which data they use.
- Protect consumers from unfair or opaque AI-driven decisions.
Although still in development, it represents a major shift toward federal oversight of AI systems in the U.S.
Federal Trade Commission (FTC)
The FTC already enforces AI fairness and consumer protection under existing laws. It can penalise companies for:
- Deceptive AI marketing (“AI-washing”).
- Misuse of personal data in AI systems.
- Unfair or discriminatory automated decisions.
The FTC has published guidelines urging companies to ensure truthful AI claims, data accuracy, and algorithmic accountability, even before dedicated AI laws are passed.
China
China’s approach to AI regulation emphasises state supervision and social stability.
Key frameworks include the Generative AI Measures (2023) and earlier Algorithmic Recommendation Provisions.
Highlights:
- Companies must register AI models with regulators before release.
- AI-generated content must reflect “core socialist values.”
- Training data must be lawful and traceable.
- Platforms must prevent fake news, bias, and harmful content.
For global companies operating in China, this means close alignment with government oversight and strict content moderation.
Japan
AI Utilization Guidelines
Japan takes a cooperative, innovation-friendly approach to AI governance. Its AI Utilization Guidelines, published by the Ministry of Economy, Trade and Industry (METI), are voluntary principles rather than strict laws.
They focus on:
- Human-centric AI development.
- Transparency and accountability in automated decision-making.
- Privacy protection aligned with Japan’s Act on the Protection of Personal Information (APPI).
- Collaboration between government, business, and academia to promote ethical AI innovation.
Japan’s approach is seen as more flexible, relying on trust and self-regulation rather than enforcement.
How Kleritt Helps Businesses Stay Compliant
At Kleritt, we help companies navigate the fast-changing world of AI compliance. Whether you operate in Europe, the U.S., or Asia, our experts ensure your AI systems meet regional requirements and ethical standards.
We assist with:
- Regulatory alignment: AI Act, GDPR, and U.S. & Asian compliance frameworks.
- Data protection: secure, privacy-first system design.
- Risk assessments: identifying and mitigating high-risk AI applications.
- Transparency & governance: clear documentation for users and regulators.
Global AI rules are evolving fast, but with the right structure, compliance can become a competitive advantage rather than a burden.
