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

What this comparison shows

On the topic of Training-Data Rights, 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: Does the EU CDSM Directive's TDM-exemption cover commercial foundation-model training? Major active litigation (NYT v OpenAI, Getty v Stability) and parallel claim regimes in UK/JP/US.