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

What this comparison shows

On the topic of Foundation Models / GPAI, EU AI Act is classified as governs and UK Pro-Innovation Approach to AI Regulation (White Paper) as implicit. 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: Does the foundation-model category map to a coherent capability tier, or is it a regulatory convenience? Compute-threshold vs behavioural-threshold debate is unresolved across EU/US/China.