Global AI regulation is evolving along two main models: risk-based frameworks, like the EU’s AI Act, which impose stricter rules on high-risk systems, and principles-based approaches, like those in India and Singapore, which rely on flexible guidelines and existing laws. The EU has the most comprehensive regime, with detailed compliance obligations, though it faces criticism for being rigid. The US follows a fragmented, pro-innovation path with federal guidance, state-level laws, and industry self-regulation. India and Singapore emphasize ethical principles, sectoral regulation, and gradual policy development, with India also tightening rules on AI-generated content.
The article was authored by Akshaya Suresh; Partner, Avani Sasindran; Associate, was published in Lexology.
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Akshaya has 17+ years of PQE. She focuses on technology laws, AI, privacy & data protection, corporate & commercial contracts, general corporate and employment matters.