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Bird & Bird: Comparing US and EU AI legislation: Divergent regulatory approaches and practical governance implications

AI regulation has emerged as one of the defining governance challenges of the 2020s, with the United States and European Union charting fundamentally different paths. Whilst the EU has enacted comprehensive product safety and fundamental rights-based legislation through the AI Act, the United States has pursued a fragmented, more innovation-permissive approach characterised by multiple state laws and limited federal guidance rather than binding federal law.

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