Artificial intelligence is moving from the zone of technological experiments to the sphere of strict state regulation. The world's leading economies already divide the market into two approaches: risk-oriented regulation with mandatory requirements and a softer model where the state bets on innovation, industry standards and post-facto control.
This topic is becoming relevant for Ukraine and other Eastern European countries. AI is already being used in banking, telecommunications, defense technology, medicine, education, government services, industry and media. Therefore, the question is no longer whether to regulate artificial intelligence, but how not to stifle innovation and at the same time protect citizens, business and the state from risks.
The most developed legal regime has already been adopted in the European Union. The EU AI Act entered into force on August 1, 2024 and is being implemented in stages. Its logic is based on risk classification: prohibited practices, high-risk AI systems, systems with transparency requirements, and general-purpose models. For countries targeting the EU market, this act effectively becomes an external standard, even if they are not members of the European Union.
South Korea became one of the first countries outside the EU to adopt a comprehensive national law on artificial intelligence. The AI Basic Act took effect in January 2026 and combines support for the AI industry with requirements for transparency, security, labeling of AI content, and oversight of high-impact systems.
China has chosen a different path — not a single universal law, but a set of mandatory rules for individual segments. The most important document was the temporary measures for the management of generative AI services, effective from 2023. The Chinese model emphasizes content control, data security, algorithm registration, verification of generative services, and compliance with state political requirements.
Japan in 2025 adopted the first national law directly dedicated to AI. However, the Japanese model is much softer than the European one: the law is primarily aimed at promoting research, development and use of artificial intelligence, rather than detailed bans and fines. This reflects Japan's desire to maintain the competitiveness of the technology sector and not create an excessive burden on business.
The US does not yet have a single federal law on artificial intelligence. Regulation develops in a piecemeal fashion: through presidential decrees, federal guidelines, NIST standards, and individual state laws. The most notable example is the Colorado AI Act, which imposes obligations on developers and users of high-risk AI systems and aims to prevent algorithmic discrimination. At the same time, at the federal level, the United States is betting on maintaining leadership, infrastructure, security, and limiting excessive regulation.
Great Britain chose the "pro-innovation regulation" model. Instead of a single AI law, London proposed a set of principles for existing regulators: security, transparency, fairness, accountability and appeals. This approach allows for faster adaptation to changes in technology, but creates less legal certainty than the European model.
Canada tried to adopt the Artificial Intelligence and Data Act as part of Bill C-27, but the bill was in the parliamentary process for a long time and did not become a full-fledged valid AI law. This shows that even advanced democracies face challenges: regulating AI simultaneously affects digital rights, business, copyright, security, competition and the labor market.
Brazil is also in the process of creating comprehensive AI regulation. The Senate approved a bill on artificial intelligence in December 2024, but it must go through the Chamber of Deputies for final approval before it can enter into force.
The Brazilian model is close to a risk-based approach, but also places a strong emphasis on human rights, copyright and developer responsibility.
Serbia is in the transition phase from strategy to mandatory regulation. The country has already adopted strategic documents on the development of AI and created a working group to prepare the first law on artificial intelligence. The new law should bring Serbia closer to the European model and provide business with clearer rules for working with AI systems.
For Ukraine, the issue of AI regulation is also becoming inevitable. On the one hand, the country needs technological modernization as quickly as possible, particularly in the fields of defense tech, govtech, medicine, cyber security, and education. On the other hand, integration into the EU market will require compatibility with the EU AI Act, especially for companies that work with European customers or export digital products.
The main crossroads for countries that have not yet adopted the laws is the choice between three models. The first is European, with strict risk classification and a high level of compliance. The second is British-Japanese, with soft regulation and an emphasis on innovation. The third is Chinese, with strong state control over content, data and algorithms.
For Eastern Europe, a hybrid model will be the most likely. Countries related to European integration or the export of IT services to the EU will be forced to take into account the EU AI Act. But due to regulators' limited resources, they are likely to introduce regulations in stages, starting with sensitive areas: civil services, biometrics, medicine, finance, education, employment and critical infrastructure.
Experts Club believes that regulation of AI will become one of the key factors in the investment attractiveness of digital economies. Companies will choose jurisdictions where the rules are clear enough for business, but do not create excessive barriers to the development and testing of new products.
It is important for Ukraine not to simply copy the EU AI Act, but to adapt it to its own capabilities. The optimal model should include a register of high-risk AI systems, regulatory sandboxes, requirements for transparency in government services, protection of personal data, labeling of synthetic content and clear rules of responsibility.
In the coming years, artificial intelligence will become the same regulated infrastructure as finance, telecommunications or energy. Countries that create clear and flexible rules earlier will have an advantage in attracting investments, developing startups and exporting digital services.
