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Comparative jurisdictional memo · Agentic AI Governance

EU AI Act vs UK Pro-Innovation Approach to AI Regulation (White Paper)

Verdict: asymmetricDownload PDF

What this comparison shows

On the topic of Agentic AI Governance, EU AI Act is classified as implicit and UK Pro-Innovation Approach to AI Regulation (White Paper) as silent. The editorial verdict is asymmetric. One regime addresses the topic explicitly while the other covers it only implicitly or not at all; this is a likely site of regulatory arbitrage and a candidate for comparative-law follow-up.

Contested question: Should governance attach to the AGENT (multi-step actions, tool use, recursion) or to the model that powers it? Capability-tier vs action-tier frames are unresolved across jurisdictions.

Bibliography

  1. Regulation (EU) 2024/1689 EU AI Act.
  2. CP 815 (2023) UK Pro-Innovation Approach to AI Regulation (White Paper).
  3. Policy Window — Agentic AI Governance (cross-jurisdiction topic article with full 26-instrument coverage matrix).

Catalog-derived comparison. Generated . No LLM-generated prose — all classifications + citations come from the typed catalog at src/lib/international-governance/instruments.ts. How this is made.

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