// wiki · review · September 2026

AI regulation abroad

Draft article. The state of the norms is as of September 2026; the stages of application of foreign laws should be checked against official texts before a decision.

The short answer

Three models have taken shape in the world. The EU adopted a horizontal risk-tiered statute — with strict duties and fines. China regulates vertically: mandatory rules for generative services and content labelling. The USA gets by with state laws and sectoral rules without a federal standard. The Russian approach is support with soft requirements (the RF regulation map). A company with an overseas audience should check how labelling rules apply to its role, product and method of distributing content.

The EU: the AI Act

Regulation (EU) 2024/1689 entered into force on 1 August 2024. The AI Act applies in phases, with different dates for individual provisions. Article 50 sets transparency obligations for particular roles and uses, not identical labelling for every item of AI content. For a product with a European audience, separately assess territorial scope, the company’s role and the obligations for each product function. Check applicable amendments and deadlines before making a decision.

China

Two layers: the rules for servicing generative AI (2023) — duties of service providers, and the measures for labelling synthetic content adopted in March 2025 and effective from 1 September 2025 together with the national standard GB 45438-2025. The requirements are stricter than the European ones: the label is double — visible to the user and hidden in metadata or watermarks — and mandatory for texts, images, audio and video; both generators and distribution platforms answer — including content created with foreign tools.

The USA

There is no federal AI law. Regulation is assembled by states: by spring 2026 more than one and a half thousand AI bills were under consideration in 45 states, and the wave moved from notifications to the “second generation” — algorithm audits, reporting, anti-discrimination requirements. Comprehensive laws — Colorado (CAIA), California, Illinois, New York with a local hiring law; the federal AI Labeling Act has not been adopted. Practically this means: requirements depend on the state of operation and the industry, without unified labelling.

Comparison and conclusions

• Content exports: separately determine the applicability of EU and Chinese rules, the company’s role and required transparency measures; a common technical label does not replace legal assessment.
• Supply chains: American and European clients carry their requirements over to suppliers — a Russian vendor will be asked about compliance with their regime.
• Dynamics: many initiatives are in the works (from the US federal labelling law to new acts of the EU Commission) — the map should be re-checked as of the date of the decision.

Checking the requirements for a specific product in target markets is the task of product rights and risks practice.