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Comparative jurisdictional memo · National Security Carveouts in AI Regulation

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

Verdict: asymmetricDownload PDF

What this comparison shows

On the topic of National Security Carveouts in AI Regulation, 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: Whether the carveout should be (a) categorical exclusion of national-security AI, (b) parallel governance track with sui generis rules, or (c) full civilian-track compliance with national-security override. Most instruments choose (a); the field debates whether this leaves a dangerous gap.

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 — National Security Carveouts in AI Regulation (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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