Global AI law: 8 common threads
About this documentUpdated 2026-09-18ShowHide
Sean McDermott, Co-Founder and CEO, UnGovr
Written by Sean McDermott (with AI assistance) using the LexLint law library, which supplied every legal instrument, status and date on these pages.
Every law named here links to its summary page on lexlint.org, translated to English (if needed) and restructured to a standard format for human and code use. Every case links to the court's or the regulator's own record where one could be reached.
© 2026 UnGovr, publishing as LexLint. The text, the figures and the theme-register file are licensed under Creative Commons Attribution-NonCommercial 4.0: share and adapt them for noncommercial purposes with credit to LexLint (UnGovr). Please contact LexLint at hello@ungovr.org to discuss commercial use. Logos and wordmarks belong to their owners.
Corpus figures as of 2026-09-18.
What the AI laws in force around the world have in common, the unusual provisions that trip an agent, the older privacy, security and scraping law that already binds one, where the new law restates the old, and why an EU-compliant system still has twenty-seven national layers to read.
1Why this paper, and who it is for
Three readers are in mind. A governance working group mapping regulatory alignment across jurisdictions, which needs a baseline of binding law to map against. Anyone who has to decide what "compliant" should mean for an AGENT, and who might reasonably assume it boils down to the EU AI Act and a handful of other acts, when the LexLint software-law corpus holds 295 AI instruments in force or enacted across 130 jurisdictions, and far more law that binds an AGENT without naming AI at all. And the engineer writing agentic software today, who wants to know which of the things the AGENT does are legal events, and where.
The paper is a summary, not an analysis of any system. It states the law as the LexLint software-law corpus held it on 2026-09-18, and it analyses only law in force or enacted with a commencement date; a proposal is named, if at all, as something coming. The larger the reach of an instrument, the more room it gets, so the EU and the United States lead most sections and a city ordinance appears once. The vocabulary is the one in Introduction: The 6 parties in AI law: the parties around a piece of software, each with a location, and an AGENT in the middle acting on most of them at once. This paper attaches the statutes to that picture.
A word on the source. LexLint is a law library first, indexed by jurisdiction and dated on every row, and it is also a tool: a lint that takes a description of what a piece of software does and where it runs and returns the obligations that apply, cited and dated, so the library can be used as background when a system is examined for legal risk. For a project that provides deep infrastructure to an application, an AGENT proxy or a runtime, that examination is harder, because the project cannot know what its USERs will do with it. What such a project can do is support the legal questions of its USERs, by giving its logs and its controls some awareness of the facts the law turns on. The fourth document in this section is about that.
2The map: what "AI law" is, by shape and by place
AI law is not one shape. Read across the LexLint software-law corpus, the instruments in force that name AI as their subject fall into six kinds, and an AGENT meets each kind differently.
| Shape | What it does | Leading examples in force |
|---|---|---|
| Horizontal acts | Define AI systems, tier them by risk, prohibit some uses, and attach duties to providers and deployers of the rest | |
| Transparency and labelling statutes | Tell the person they are dealing with a machine; mark what the machine produced, often in a machine-readable way | |
| Automated-decision and employment rules | Govern a decision about a person made with a system: notice, an impact assessment, a bias audit, a way to contest | New York City's bias-audit law (since 2023-01-01); |
| Model-level and frontier duties | Bind the party that trains or places a model: documentation, a training-content summary, safety frameworks, incident reporting | |
| Companion and conversational systems | Rules for systems that talk to people as if they were people: reminders, minors, self-harm protocols, no posing as a human | |
| Synthetic-content harms in criminal and election law | The largest number of instruments by far: intimate-image and child-abuse offences extended to generated imagery, and election deepfake rules |
By place, the LexLint software-law corpus holds AI instruments in the regions below. The count is of instruments the corpus holds in force or enacted, which is a measure of law rather than of any one country's attention; the largest single share is the American states' own statute books, and the largest single instrument is the EU's.
| Region | AI instruments in force or enacted | Jurisdictions |
|---|---|---|
| European Union | 5 | 1 |
| EU member states (the national layer) | 34 | 22 |
| United Kingdom | 1 | 1 |
| United States, federal | 0 | 0 |
| United States, states | 177 | 48 |
| United States, cities | 12 | 12 |
| Asia and the Pacific | 23 | 13 |
| The Americas outside the United States | 14 | 8 |
| Africa, the Middle East and elsewhere | 29 | 25 |
Every AI instrument the LexLint software-law corpus holds in force or enacted is listed in the appendix at the end of this page, by region, each linked to its summary page.
The zero on the United States' federal row is a finding rather than a gap. Congress has enacted no horizontal AI act, and the two federal AI instruments the corpus holds are both proposals, so neither is counted here. It does not mean no federal law reaches generated content: the TAKE IT DOWN Act criminalises publishing intimate images a system generated, and people have been prosecuted under it. The corpus files that statute under privacy rather than AI, which is why it is absent from this table and present in Does legal action really happen?. Read the row as "no federal AI statute", never as "no federal law".
3What the laws have in common
Eight threads run through most of the AI law in force. An engineer who builds for the threads rather than for any one statute will find that most statutes are then a matter of parameters.
Tell the person they are dealing with a machine
The most widely shared duty, and the oldest of the new ones. AI Act Article 50 requires it of any system that interacts with people unless it is obvious from context; Korea's Article 31 requires prior notice that a service runs on generative AI; Texas, Utah and California's 2019 bot-disclosure act each say it in their own terms, and California's companion chatbot act adds a duty to repeat the reminder to a minor. The differences are in the trigger (always, on request, at first use, on a schedule) and in who owes it (provider, deployer, OPERATOR).
Mark what the machine made
A second duty attaches to the output rather than the interaction: machine-readable marking of synthetic audio, image, video and text. It is in Article 50(2), in India's rules, which require permanent metadata with a unique identifier, in Vietnam's transparency article, and in California's AI Transparency Act. For an AGENT the consequence is architectural: the mark has to be applied where the output is produced and preserved by every layer that carries it.
Tier by risk, with a prohibited top
The horizontal acts share a shape: a list of prohibited practices, a class of high-risk or high-impact uses with the heaviest duties, and a lighter regime for the rest. Vietnam and Peru both open with prohibitions; Texas's TRAIGA is almost entirely a list of them, binding any person. Prohibition is how the law tiers: the LexLint software-law corpus's AI instruments carry more prohibition lines than any other class.
Keep a person able to intervene, and give affected people a way to one
Human oversight appears in two forms: a duty on the OPERATOR to keep a person able to stop or override the system, and a right for the person affected by a decision to reach a human and contest it. The second form is older than AI law and arrives mostly through privacy statutes (section 5). The first is the AI Act's Article 14, Vietnam's rule that oversight mechanisms must not be disabled, and Peru's bar on autonomous lethal capability without supervision.
Keep records, and be able to explain
Record-keeping comes in three registers: automatic event logs for high-risk systems (the AI Act's Article 12, with a six-month retention floor on deployers in Article 26), an explanation to the person affected by a decision (Peru, California's regulations), and documentation kept for a regulator (Article 53, California's frontier act). The logging and record-keeping questions a governance framework asks are these three duties, seen from the OPERATOR's side.
Assign duties by role along a chain
The AI Act names a provider, a deployer, an importer, a DISTRIBUTOR, an authorised representative and a product manufacturer for one system, a seventh role for general-purpose model providers, and a rule in Article 25 under which a deployer, DISTRIBUTOR or importer becomes the provider by putting its name on a high-risk system, substantially modifying it, or changing a system's purpose so that it becomes high-risk. Korea's act keys on the "AI business operator"; the United States state acts on the "deployer" and the "developer". One company usually holds three of these roles at once, and the role, not the code, decides the duty.
Reach by market and by output, not by where the server is
The AI Act reaches a provider anywhere that places a system on the EU market and a provider or deployer anywhere whose output is used in the Union. State acts reach a company that does business in the state when the consumer is a resident. Korea's act reaches acts abroad that affect its market. The server's location is the one fact none of them turns on.
Commence in stages, and change while in flight
The AI Act applies in dated stages from 2025-02-02 to 2028-08-02, and the omnibus regulation of July 2026 moved the high-risk stages back by more than a year while leaving the transparency duties on their August 2026 date. Colorado enacted an AI act in 2024, delayed it in 2025, and repealed and re-enacted it in 2026 before a line of it applied, as an automated-decision act that applies from 2027-01-01. A map of AI law is a dated artefact, and a system that reads the map once is out of date the month after. More is coming: Brazil's framework bill has passed its Senate, and several EU member states have implementing acts in draft (section 7).
4Provisions that are unusual, and awkward for an AGENT
The common threads are what a framework captures. The provisions below are the ones a framework does not, because each is one jurisdiction's own idea, and each lands on something an AGENT does routinely. The EU comes first, then the United States by state, then the rest of the world by name.
| Where | Provision | What is unusual | Why it is awkward for an AGENT |
|---|---|---|---|
| AI Act, Article 50 (transparency obligations for AI systems and synthetic content) (since 2026-08-02) | A fine of up to EUR 15 million or 3 percent of worldwide turnover, whichever is higher, and for a small or medium enterprise whichever is lower | The ceiling depends on which party in the chain is the addressee and how large it is, which for an AGENT built by a start-up on a large provider's model is two different answers | |
| Companion Chatbot Safety and Accountability Act (SB 243) (since 2026-01-01) | For companion chatbots: a protocol for suicidal ideation, reminders to minors that they are talking to a machine, and a private right of action | Any AGENT with a persona and memory can become a companion in the statute's sense without having been designed as one | |
| Generative AI Training Data Transparency Act (AB 2013) (since 2026-01-01) | A public summary of the training data behind a generative system, with no regulator and no penalty in the statute | An AGENT assembled from several models inherits several summaries, and the duty attaches to whoever makes the system available in California | |
| HB 26-1263 (2026), Conversational AI Service Operator Requirements (from 2027-01-01) | A separate statute for OPERATORs of conversational AI services, beside the automated-decision act, both from 2027 | An AGENT that both talks to a person and decides about them falls under two Colorado regimes with two sets of duties and one Attorney General | |
| Artificial Intelligence Video Interview Act (since 2020-01-01) | Consent before AI analyses a recorded video interview, an explanation of how it works, deletion on request within thirty days, and a report on demographics where AI decides who gets an in-person interview | Voice and video analysis by an AGENT is the regulated act, whether or not the product calls itself an interview tool | |
| Artificial Intelligence Companion Models safeguards (since 2025-11-07) | Safeguards for companion models, with a penalty of up to US$ 15,000 per day | A per-day penalty on a feature that runs continuously | |
| New York City | Automated Employment Decision Tools Bias Audit and Notice Law (since 2023-01-01) | An independent bias audit, published, before an automated employment decision tool is used, and notice to candidates | An AGENT that screens applicants is the tool; the audit is of the tool's outputs, which for an AGENT are not fixed |
| TRAIGA (H.B. 149, 2025), prohibited AI practices binding any person (since 2026-01-01) | Prohibitions keyed on intent (to manipulate, to discriminate, to produce unlawful content), enforced only by the Attorney General, with penalties up to US$ 200,000 for an uncurable violation and per-day penalties for continuing ones | Intent is the developer's or deployer's, but the conduct is the AGENT's. The record of why an AGENT did something is the evidence on both sides | |
| SB 226 (2025), required disclosures for generative AI in consumer transactions (since 2025-05-07); HB 452 (2025), mental health chatbot disclosure | Disclosure of generative AI in a consumer transaction when asked, and always for regulated occupations; a separate mental-health chatbot rule | "When asked" means the AGENT must recognise the question in any phrasing and answer it truthfully, mid-task | |
| Synthetically Generated Information Labelling Duty for Intermediaries (since 2026-02-10) | Synthetic content must carry permanent metadata or technical provenance with a unique identifier | "Permanent" is the hard word: any transformation the AGENT applies downstream has to preserve an identifier it did not create | |
| AI Framework Act, Article 31 (transparency obligations for AI outputs) (since 2026-01-22) | Prior notice that a product or service operates on high-impact or generative AI, before the USER interacts | The notice comes before the interaction, so an AGENT invoked by another system has to have been announced by that system, not by itself | |
| Reglamento de la Ley 31814, high-risk AI system duties (since 2026-01-22) | Before the interaction, tell the USER the system's purpose, its main functions and what decisions it can make; explain rights-affecting results in accessible language | An AGENT's "what decisions it can make" is its tool set and its autonomy budget. Few AGENTs can state that list to a USER, and it changes per task | |
| Law on Artificial Intelligence, prohibited practices; risk classification articles (since 2026-03-01) | A prohibition on obstructing, disabling or distorting the human-oversight mechanisms the law requires; a duty to re-classify the system when its function changes | An AGENT that reconfigures its own tools or is given a new one has changed function; an AGENT that routes around an approval step has touched an oversight mechanism |
5The law that was already there
Most attention is on the AI statutes, and above all on the EU AI Act. But the LexLint software-law corpus holds far more law that binds an AGENT without naming AI at all. Privacy law is the largest topic in it, scraping and access law the second, and both are older than any AI act. The table under each heading gives the duty family, an instrument in the corpus, and what the duty asks of an AGENT in particular.
5.1 Privacy law: the AGENT as a processor of people
787 instruments in force or enacted, across 235 jurisdictions. Every one of them keys on a person whose data is in the payload, which for an AGENT is nearly every payload.
| Duty family | Instruments in the LexLint software-law corpus | What it asks of an AGENT |
|---|---|---|
| Decisions made by a machine | GDPR Articles 12 to 22, with Article 22's right not to be subject to a solely automated decision; the United Kingdom's 2025 rewrite of that right; California's automated decision-making regulations; Colorado's privacy act and its profiling opt-out; Brazil's LGPD (the general data protection law) with its Article 20 review right | When the AGENT decides about a person (a refund, a shortlist, a price, an account action), the person may be owed notice, an explanation, a human review and a way to contest. The LexLint software-law corpus holds automated-decision lines in 110 jurisdictions |
| Lawful basis, purpose and minimisation | The GDPR; Japan's APPI; Canada's PIPEDA; California's CCPA; Virginia's act; Texas's act | An AGENT that reads an inbox to plan a week has a purpose for the correspondents' data that none of them agreed to. What it retains, and where, is the minimisation question |
| Sensitive data and biometrics | GDPR Article 9; Illinois's BIPA and its private right of action; Virginia's sensitive-data consent | A voiceprint derived to tell speakers apart, or a face matched in a photo, is a biometric identifier. Illinois requires written consent first and lets the person sue per violation |
| Cross-border transfer | GDPR Chapter V; Japan's Article 28; the United Kingdom's transfer rules | Every model call and every tool call has a destination. If the payload carries personal data and the destination is abroad, the call is a transfer |
| Breach notification | GDPR Articles 33 and 34; California's breach law; the HIPAA breach rule; the GLBA safeguards amendment; Australia's notifiable breaches scheme | An AGENT that sends the wrong document to the wrong recipient has caused a breach. The clock starts on awareness, and the log is what says what left |
5.2 Cybersecurity law: the AGENT as a product and as an incident
| Duty family | Instruments in the LexLint software-law corpus | What it asks of an AGENT |
|---|---|---|
| Risk management and incident reporting for OPERATORs of essential services | NIS2, Article 21 and Article 23 (early warning within 24 hours, notification within 72) | An AGENT with credentials to production systems is part of the attack surface those measures cover, and an AGENT acting on an injected instruction is an incident |
| Product security and vulnerability handling for the MAKER of software | The CRA, Article 13 and Annex I (from 2027-12-11); Article 14 (since 2026-09-11), an actively exploited vulnerability reported within 24 hours | The first horizontal law to make the MAKER of software an addressee. An AGENT shipped as a product is a product with digital elements, and prompt injection is a vulnerability class its manufacturer must handle |
5.3 Scraping, access and content law: the AGENT as a visitor on other people's machines
498 instruments in force or enacted, across 245 jurisdictions. This is the body of law an AGENT meets every time it fetches a page, calls an interface it was not invited to, or reuses what it found.
| Duty family | Instruments in the LexLint software-law corpus | What it asks of an AGENT |
|---|---|---|
| Computer misuse and unauthorised access | The Computer Fraud and Abuse Act; Singapore's Computer Misuse Act; Germany's Criminal Code sections 202a to 303b | Whether access was authorised is decided by the COUNTERPARTY's gates: a login, a block, a revoked permission. An AGENT that works around any of them has crossed a line the statute draws |
| Text and data mining reservations | The EU copyright directive's Article 4; Germany's section 44b; AI Act Article 53, which makes a general-purpose model provider honour the reservation | A rightsholder's machine-readable reservation binds the fetch and the training use. An AGENT that reads a page to answer a question is mining it; whether that is covered depends on the reservation and the purpose |
| Database rights and unfair competition | Germany's database right; Austria's unfair-practices clause | Systematic extraction of a substantial part of somebody's database is a wrong in itself in the EU, whatever the terms said |
| Personal data on public pages | Illinois's consent duty for scraped faces; Australia's reach over scraped personal information; Korea's rule as applied by its regulator | "It was public" is not a lawful basis. The names on a page are personal data, and copyright has nothing to say about them |
5.4 Consumer, contract and outreach law: the AGENT as a contracting party's instrument and as a caller
| Duty family | Instruments | What it asks of an AGENT |
|---|---|---|
| Unfair and deceptive practices | FTC Act section 5; California's bot-disclosure act | What the AGENT says to a consumer is what the company said. A claim about what the AGENT can do is an advertising claim about the product |
| Contracts formed by machines | Indonesia's electronic-agent liability rule; the United States electronic-signature statute and the state UETA, under which a contract may be formed by the interaction of electronic AGENTs with no person reviewing it; Article 12 of the 2005 United Nations convention on electronic contracting, which says the same of automated message systems | When an AGENT clicks "buy", a contract is formed and the principal is bound. Who bears a mistaken purchase is a question the electronic-agent rules answer, and the answer is usually the principal |
| Automated calls and messages | The United States TCPA, which the Federal Communications Commission ruled on 2024-02-08 covers calls made with an AI-generated voice; the consent rules for marketing email and text in most jurisdictions | An outbound voice AGENT is a robocall. A drafted email the AGENT also sends is marketing mail if it markets. Consent and an opt-out are the price of the channel |
5.5 Sector and people-specific law
| Domain | Instruments in the LexLint software-law corpus | What it asks of an AGENT |
|---|---|---|
| Employment | New York City's bias-audit law; Illinois's Human Rights Act amendment; New Jersey's disparate-impact rules; Spain's works-council right to algorithm parameters | An AGENT that screens, schedules, scores or dismisses workers is an employment decision tool, with notice, audit and disclosure duties that predate any AI act |
| Children | The Children's Online Privacy Protection Act and its 2025 rule; the DSA, Article 28; the United Kingdom's children's code; Texas's age-verification law | The principal's age and location at access decide which of these applies. An AGENT that cannot tell it is talking to a child is talking to one |
| Health and finance | The HIPAA privacy rule; the GLBA safeguards rule; Texas's AI diagnostic disclosure; California's patient-communication disclosure; the ECOA adverse-action notice, which applies however a credit decision was made | Sector law attaches to the data and the decision, not to the technology. An AGENT in a clinic or a lender is inside those regimes on its first day |
6Where the AI laws restate what was already required
Read against section 5, a large share of the new AI law is a restatement or a refinement of a duty the same jurisdiction already had, aimed at a new class of system. That is good news for an engineering team, because a control built for the old duty is usually most of the new one. The table pairs them.
| The AI-law duty | The duty that was already there, same jurisdiction | What the AI law adds |
|---|---|---|
| GDPR Articles 13 and 14, information to be given when personal data is collected; the unfair commercial practices rules on misleading omissions | The duty fires on every interaction whether or not personal data is involved, and adds machine-readable marking of the output | |
| GDPR Article 22, the right not to be subject to a solely automated decision, and Article 15's right to meaningful information about the logic | A duty on the deployer to design oversight in, and an explanation right that does not depend on the decision being "solely" automated | |
| The Colorado Privacy Act's right to opt out of profiling in furtherance of decisions with legal or similarly significant effects | Duties on the developer and the deployer of the technology itself, not only rights for the consumer | |
| The CCPA itself: the regulations are made under it | Pre-use notice, an opt-out and access rights specific to automated decision-making technology, and risk assessments for it | |
| The 2019 bot-disclosure act, which made it unlawful to use a bot with intent to mislead about its identity in sales or elections | Marking of the output itself, a detection tool, and a penalty per violation, with no intent element | |
| The Personal Information Protection Act's 2023 amendments, which gave data subjects a right to refuse or demand an explanation of a fully automated decision | A notice duty on the OPERATOR that does not depend on personal data or on a decision being made | |
| The Illinois Human Rights Act's existing prohibition on discrimination, and the 2020 video-interview act | A notice duty and an express statement that using AI in a way that has a discriminatory effect is a civil rights violation | |
| New York City: the bias-audit law | The city's Human Rights Law, which already prohibited discriminatory hiring however it was done | A procedural duty, the audit and the notice, that makes the substantive one checkable before the harm |
| The Data (Use and Access) Act 2025 rewrote the automated-decision right | Nothing: the United Kingdom's AI duty arrives as a privacy amendment, which is the pattern in its purest form |
7The EU: "AI Act compliant" is not "compliant in the EU"
The AI Act is a regulation, directly applicable in every member state, and that has led to a habit of treating it as the whole of EU AI law. It is not, for two reasons the LexLint software-law corpus makes visible.
First, the Act leaves to each member state the designation of its market surveillance and notifying authorities, the procedure they follow, the penalties within the Act's ranges, and the treatment of public bodies. Those choices are national statutes, and they differ: which authority a provider answers to, what powers it has, whether a public body can be fined and by how much, and how the prohibitions in Article 5 are enforced. A system that is compliant with the Act has to be compliant with it in front of a named authority under a named procedure, and there are twenty-seven of those.
Implementing acts are in draft in Spain, Luxembourg, Netherlands, Sweden, Slovakia; they are not analysed here.
Second, member states keep their own law on what AI systems produce and how they are used at work, and that law is not displaced by the Act. Italy's Law 132 of 2025 requires parental consent for under-fourteens, sets sector rules for oversight and disclosure, and creates a criminal offence for disseminating harmful generated content. France, Ireland, the Netherlands and most other member states have extended their intimate-image and child-abuse offences to generated material. Spain gives works councils a right to the parameters of algorithms that affect working conditions. None of this is in the AI Act, all of it binds an AGENT operating in that country, and the omnibus regulation of July 2026 changed none of it.
The practical reading: EU compliance for an AGENT is the Act, plus the implementing act of every member state whose market it is placed on or whose residents' output it produces, plus that state's own criminal, labour and consumer law on synthetic content and automated management. The LexLint corpus documents the national layer on each member state's page rather than restating the Act there; the Act is one instrument, held once.
8How the law reaches the AGENT
Put the statutes onto the second figure of the parties document, and each line out of the AGENT's box collects a family of law. The table is the whole paper in one place.
| What the AGENT does | Whose position triggers scope | Law families that attach | Examples |
|---|---|---|---|
| Answers, shows output to the person who asked | The principal; where the output is used | Interaction disclosure; content marking; companion rules; consumer protection | AI Act Article 50; Korea Article 31; California's companion act |
| Decides about a person, or scores them | The affected person's residence | Automated-decision rights; employment, credit and insurance rules; impact assessments | GDPR Article 22; Colorado's act; New York City's audit law |
| Remembers, stores, infers | The data subject's residence; the OPERATOR's establishment | Lawful basis, minimisation, retention, sensitive data, breach | The GDPR; BIPA; Virginia's sensitive-data rule |
| Reads pages, calls interfaces it was not invited to | The COUNTERPARTY's location and terms | Computer misuse; text-and-data-mining reservations; database rights; terms of service | The Computer Fraud and Abuse Act; Germany's section 44b |
| Calls a model or a tool provider | The provider's establishment; the destination of the call | Processor contracts; cross-border transfer; the provider's own model duties | GDPR Chapter V; AI Act Article 53 |
| Sends, posts, submits, pays | The recipient's location; the platform's rules; the COUNTERPARTY's terms | Outreach and telemarketing rules; platform policies; contract formation by electronic AGENTs; payment rules | The TCPA and the 2024 AI-voice ruling; Indonesia's electronic-agent rule |
| Acts in the OPERATOR's name on its systems | The OPERATOR's establishment | Security duties; sector regimes; the OPERATOR's own role under the AI Act as deployer or provider | NIS2 Article 21; the Cyber Resilience Act |
| Is offered through a store, a registry, an interface | Where it is placed on the market | Product safety and liability; market access; store rules by contract | The AI Act's provider duties; Cyber Resilience Act Article 14 |
| Leaves a record, or fails to | Whichever party a regulator asks about | Record-keeping, logging, audit, breach evidence | The AI Act's Article 12; GDPR Articles 33 and 34 |
One AGENT, six instruments
Take an AGENT operated by a company whose main establishment is in the United States, offered to consumers in Ireland and Virginia, built on a general-purpose model its provider placed on the EU market, that answers questions by fetching pages from a German publisher and stores USER prompts that sometimes include the USER's location. Six instruments reach it, each through a different party.
| Instrument | Whom it binds | The hook that reaches this AGENT |
|---|---|---|
| OPERATOR as controller | Targeting data subjects in the Union; the Irish USER is the data subject | |
| OPERATOR as controller | The national act that supplements the GDPR for that data subject | |
| OPERATOR as deployer; the model provider, a MAKER, as provider | Output used in the Union; the model placed on the EU market | |
| The model provider alone, a MAKER | A general-purpose model placed on the EU market | |
| OPERATOR as the party mining; the publisher, a COUNTERPARTY, may have reserved | The reproduction happens against a German rightsholder's pages | |
| OPERATOR as controller | Products targeted to Virginia residents; a stored location is sensitive data, consent required |
Swap the Irish USER for one in Seoul and the AI rows change to Korea's Article 31; swap Virginia for Texas and the privacy row becomes Texas's sensitive-data consent. Nothing about the OPERATOR changed. One field in the request did, which is why the applicability question is answered per transaction from facts the AGENT either recorded or lost.
What a control on the request path can do about it
Of the requirement lines in force that an independent classification has reached (2,286 on 2026-09-18), 47% can be prevented by a control on the request path (refuse a destination, require a claim, transform a payload), 16% can be detected there but are discharged in the application's interface or process, 8% are performed elsewhere with the control's record as the evidence, and 28% never cross the request path at all: lawful basis, conformity assessment, registration, contracts. By topic the pattern is sharp: scraping law is overwhelmingly enforceable at the edge, AI law is mostly detectable, since its disclosure and marking duties close in the interface, and the out-of-path share of privacy law is what has to be staffed rather than engineered. A control that sits in the enforceable tier is a technical measure, not a finding that the duty is met.
9What it costs
The enforcement examples this paper would otherwise carry are in their own document, Does legal action really happen?, each starting from an ordinary product feature and ending in a figure with its primary source. The LexLint corpus also records the enforcement climate of a regime where a regulator or a tracker publishes one; the figures below, read on the date shown, say the powers are used.
| Regime | What is recorded | As of |
|---|---|---|
European Union |
Fines in the last year: EUR 870,000,000. Actions in the last year: 3. Trend: rising. Source | 2026-09-17 |
European Union |
Fines in the last year: EUR 870,000,000. Actions in the last year: 3. Trend: rising. Source | 2026-09-17 |
Austria |
Fines in the last year: EUR 145,000. Actions in the last year: 58. Trend: falling. Source | 2026-09-02 |
European Union |
Fines to date: EUR 6,110,000,000. Fines in the last year: EUR 487,600,000. Actions in the last year: 440. Trend: rising. Source | 2026-09-02 |
European Union |
Fines to date: EUR 6,110,000,000. Fines in the last year: EUR 487,600,000. Actions in the last year: 440. Trend: rising. Source | 2026-09-02 |
European Union |
Fines to date: EUR 6,110,000,000. Fines in the last year: EUR 487,600,000. Actions in the last year: 440. Trend: rising. Source | 2026-09-02 |
European Union |
Fines to date: EUR 6,110,000,000. Fines in the last year: EUR 487,600,000. Actions in the last year: 440. Trend: rising. Source | 2026-09-02 |
European Union |
Fines to date: EUR 6,110,000,000. Fines in the last year: EUR 487,600,000. Actions in the last year: 440. Trend: rising. Source | 2026-09-02 |
European Union |
Fines to date: EUR 6,110,000,000. Fines in the last year: EUR 487,600,000. Actions in the last year: 440. Trend: rising. Source | 2026-09-02 |
Greece |
Fines in the last year: EUR 4,302,149. Actions in the last year: 46. Source | 2026-09-02 |
Croatia |
Fines to date: EUR 10,500,000. Source | 2026-09-02 |
Hungary |
Fines in the last year: HUF 67,195,000. Actions in the last year: 1,005. Source | 2026-09-02 |
Ireland |
Fines in the last year: EUR 530,770,000. Actions in the last year: 4. Source | 2026-09-02 |
Ireland |
Fines in the last year: EUR 530,770,000. Actions in the last year: 4. Source | 2026-09-02 |
Ireland |
Fines in the last year: EUR 530,770,000. Actions in the last year: 4. Source | 2026-09-02 |
Ireland |
Fines in the last year: EUR 530,770,000. Actions in the last year: 4. Source | 2026-09-02 |
Ireland |
Fines in the last year: EUR 530,770,000. Actions in the last year: 4. Source | 2026-09-02 |
Ireland |
Fines in the last year: EUR 530,770,000. Actions in the last year: 4. Source | 2026-09-02 |
Italy |
Fines in the last year: EUR 24,000,000. Actions in the last year: 835. Trend: rising. Source | 2026-09-02 |
Liechtenstein |
Fines in the last year: CHF 21,500. Actions in the last year: 3. Source | 2026-09-02 |
Lithuania |
Fines in the last year: EUR 27,029. Actions in the last year: 5. Source | 2026-09-02 |
Malta |
Fines in the last year: EUR 17,500. Actions in the last year: 2. Trend: flat. Source | 2026-09-02 |
Norway |
Fines in the last year: NOK 4,250,000. Actions in the last year: 4. Trend: falling. Source | 2026-09-02 |
Poland |
Fines in the last year: PLN 64,436,940.25. Actions in the last year: 20. Trend: rising. Source | 2026-09-02 |
Portugal |
Fines in the last year: EUR 47,000. Actions in the last year: 2. Trend: falling. Source | 2026-09-02 |
Sweden |
Fines in the last year: SEK 250,000. Actions in the last year: 3. Trend: falling. Source | 2026-02-18 |
Slovenia |
Fines in the last year: EUR 47. Actions in the last year: 91. Trend: flat. Source | 2026-09-02 |
Turkey |
Fines in the last year: TRY 352,510,494. Actions in the last year: 876. Trend: falling. Source | 2026-09-02 |
10What this paper does not claim
It does not say which of these instruments binds any particular system; that is decided per deployment from the roles the system's OPERATOR holds and where its parties are. It analyses law in force or enacted on the date the LexLint software-law corpus was read, and a law that moved after it may have moved the answer. The appendix is a list of what the corpus holds, not a census of the world's law. Nothing here is legal advice.
Appendix: every AI instrument in force or enacted, by region
Read from the LexLint software-law corpus on 2026-09-18. Each name links to the summary page carrying its citation, status, commencement date and source.
European Union: 5 instruments in 1 jurisdictions
| Jurisdiction | Instrument | Since / from | Asks of an app |
|---|---|---|---|
| AI Act, Article 50 (transparency obligations for AI systems and synthetic content) | 2026-08-02 | label generated content; disclose the use of ai | |
| AI Act, Article 53 (obligations for providers of general-purpose AI models) | 2025-08-02 | disclose the use of ai; govern the system: policies, roles, assessments; respect text and data mining opt-outs | |
| AI Act, Article 73 (reporting of serious incidents) | 2026-08-02 | ||
| Digital Services Act, Article 35(1)(k) (systemic risk mitigation, synthetic media marking) | 2023-08-25 | label generated content; govern the system: policies, roles, assessments; assess the impact on personal data first | |
| Digital Services Act, Article 37 (independent audit of very large online platforms and search engines) | 2023-08-25 | govern the system: policies, roles, assessments; report to a regulator |
EU member states (the national layer): 34 instruments in 22 jurisdictions
United Kingdom: 1 instruments in 1 jurisdictions
| Jurisdiction | Instrument | Since / from | Asks of an app |
|---|---|---|---|
| Creating, or Requesting the Creation of, Purported Intimate Image of Adult | 2026-02-06 |