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AI Watch: Global regulatory tracker

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Keeping track of AI regulatory developments around the world.

The global dash to regulate AI

Artificial intelligence (AI) has made enormous strides in recent years and has increasingly moved into the public consciousness.

Increases in computational power, coupled with advances in machine learning, have fueled the rapid rise of AI. This has brought enormous opportunities, as new AI applications have given rise to new ways of doing business. It has also brought potential risks, from unintended impacts on individuals (e.g., AI errors harming an individual's credit score or public reputation) to the risk of misuse of AI by malicious third parties (e.g., by manipulating AI systems to produce inaccurate or misleading output, or by using AI to create deepfakes).

Governments and regulatory bodies around the world have had to act quickly to try to ensure that their regulatory frameworks do not become obsolete. In addition, international organizations such as the G7, the UN, the Council of Europe and the OECD have responded to this technological shift by issuing their own AI frameworks. But they are all scrambling to stay abreast of technological developments, and already there are signs that emerging efforts to regulate AI will struggle to keep pace. In an effort to introduce some degree of international consensus, the UK government organized the first global AI Safety Summit in November 2023, with the aim of encouraging the safe and responsible development of AI around the world. 

Most jurisdictions have sought to strike a balance between encouraging AI innovation and investment, while at the same time attempting to create rules to protect against possible harms. However, jurisdictions around the world have taken substantially different approaches to achieving these goals, which has in turn increased the risk that businesses face from a fragmented and inconsistent AI regulatory environment. Nevertheless, certain trends are becoming clearer at this stage:

  1. "AI" means different things in different jurisdictions: One of the foundational challenges that any international business faces when designing an AI regulatory compliance strategy is figuring out what constitutes "AI." Unfortunately, the definition of AI varies from one jurisdiction to the next. For example, the draft text of the EU AI Act adopts a definition of "AI systems" that is based on (but is not identical to) the OECD's definition, and which leaves room for substantial doubt due to its uncertain wording. Canada has proposed a similar, though more concise, definition. Various US states have proposed their own definitions, which differ from one another. And many jurisdictions (e.g., the UK, Israel, China, and Japan) do not currently provide a comprehensive definition of AI. Because several of the proposed AI regulations have extraterritorial effect (meaning more than one AI regulation may apply simultaneously), international businesses may be forced to adopt a "highest common denominator" approach to identifying AI based on the strictest applicable standard.
  2. Emerging AI regulations come in different forms: The various emerging AI regulations have no consistent legal form – some are statutes, some are executive orders, some are expansions of existing regulatory frameworks, and so on. The EU AI Act is a "Regulation" (which means that most of it will apply directly in all EU Member States, without the need for national implementation in most cases). The UK has taken a different approach, declining to legislate at this early stage in the development of AI, and instead choosing to task existing UK regulators with the responsibility of interpreting and applying five AI principles in their respective spheres. In the US, there is a mix of White House Executive Orders, federal and state initiatives, and actions by existing regulatory agencies, such as the Federal Trade Commission. As a result, the types of compliance obligations that international businesses face are likely to be materially different from one jurisdiction to the next. Many other jurisdictions have yet to decide whether they will issue sector-specific or generally applicable rules and have yet to decide between creating new regulators or expanding the roles of existing regulators, making it challenging for businesses to anticipate what form their AI regulatory relationships will take in the long term.
  3. Emerging AI regulations have different conceptual approaches: The next difficulty is the lack of a consistent conceptual approach among emerging AI regulations around the world – some are legally binding while others are not, some are sector-specific while others apply across all sectors, some will be enforced by regulators while others are merely guidelines or recommendations, and so on. As noted above, the UK approach is to use existing regulators to implement five AI principles, but with no new explicit legal obligations. This has the advantage of meaning that businesses will deal with AI regulators with whom they are already familiar but has the disadvantage that different UK regulators may interpret these principles differently in their respective spheres. The EU AI Act is cross-sectoral and creates new regulatory and enforcement powers for existing bodies, including the European Commission, and also creates entirely new bodies such as the AI Board and the AI Office, while leaving EU Member States to appoint their own AI regulators tasked with enforcing the AI Act. In the US, the Federal Trade Commission, Equal Employment Opportunity Commission, Consumer Financial Protection Bureau, and Department of Justice issued a joint statement clarifying that their existing authority covers AI, while various state regulators are also likely to have competence to regulate AI. International organizations including the OECD, the UN, and the G7 have issued AI principles, but these impose no legal obligations on businesses. In principle, these initiatives encourage consistency across members of each organization, but in practice this does not seem to have worked.
  4. Flexibility is a double-edged sword: In an effort to create AI regulations that can adapt to technological advances that have not yet been anticipated, many jurisdictions have sought to include substantial flexibility in those regulations, either by using deliberately high-level wording and policies, or by allowing for future interpretation and application by courts and regulators. This has the obvious advantage of prolonging the lifespan of such regulations by allowing them to be adapted to future technologies. However, it also creates the disadvantage of uncertainty because it leaves businesses uncertain of how their compliance obligations will be interpreted in the future. This is likely to mean that it is harder for businesses to know whether their planned implementations of AI will be lawful in the medium-to-long term and may make it harder to attract long-term AI investment in those jurisdictions.
  5. The overlap between AI regulation and other areas of law is complex: A substantial number of laws that are not directly focused on AI nevertheless apply to AI by association within their respective spheres, meaning that any use of AI will often trigger compliance issues and legal challenges even where there is not (yet) any enforceable AI-specific law. These areas of overlap include: IP (e.g., IP infringement issues with respect to AI model training data, and questions about copyright and patentability of AI-assisted inventions); antitrust; data protection (which adds restrictions to processing of personal data, and in some cases imposes special compliance obligations for processing carried out by automated means, including by AI); M&A (where AI innovation is driving dealmaking in many markets); financial regulation (where financial regulatory requirements may limit the ways in which AI can lawfully be deployed); litigation; digital infrastructure; securities; global trade; foreign direct investment; mining & metals; and so on. This overlap will mean that many businesses need to understand not just AI regulations in general, but also any rules that affect the use of AI in the context of the relevant sector or business activity.

Businesses in almost all sectors need to keep a close eye on these developments to ensure that they are aware of the AI regulations and forthcoming trends, in order to identify new opportunities and new potential business risks. But even at this early stage, the inconsistent approaches each jurisdiction has taken to the core questions of how to regulate AI is clear. As a result, it appears that international businesses may face substantially different AI regulatory compliance challenges in different parts of the world. To that end, this AI Tracker is designed to provide businesses with an understanding of the state of play of AI regulations in the core markets in which they operate. It provides analysis of the approach that each jurisdiction has taken to AI regulation and provides helpful commentary on the likely direction of travel.

Because global AI regulations remain in a constant state of flux, this AI Tracker will develop over time, adding updates and new jurisdictions when appropriate. Stay tuned, as we continue to provide insights to help businesses navigate these ever-evolving issues.



Voluntary AI Ethics Principles guide responsible AI development in Australia, with potential reforms under consideration.



The enactment of Brazil's proposed AI Regulation remains uncertain with compliance requirements pending review.

Sao Paulo


AIDA expected to regulate AI at the federal level in Canada but provincial legislatures have yet to be introduced.



The Interim AI Measures is China's first specific, administrative regulation on the management of generative AI services.


Council of Europe

The Council of Europe is developing a new Convention on AI to safeguard human rights, democracy, and the rule of law in the digital space covering governance, accountability and risk assessment.

European Union

European Union

The EU introduces the pioneering EU AI Act, aiming to become a global hub for human-centric, trustworthy AI.


European Union


France actively participates in international efforts and the EU AI Act negotiations, and proposes sector-specific laws.



The G7's AI regulations mandate Member States' compliance with international human rights law and relevant international frameworks.

G7 flags


Germany evaluates AI-specific legislation needs and actively engages in international initiatives.



National frameworks inform India’s approach to AI regulation, with sector-specific initiatives in finance and health sectors.



Israel promotes responsible AI innovation through policy and sector-specific guidelines to address core issues and ethical principles.



Italy plays a prominent role in EU AI Act negotiations and engages in political discussions for future laws.



Japan adopts a soft law approach to AI governance but lawmakers advance proposal for a hard law approach to generative AI foundation models.



Position paper informs Norwegian approach to AI, with sector-specific legislative amendments to regulate developments in AI.



The OECD's AI recommendations encourage Member States to uphold principles of trustworthy AI.

country flags


Singapore's AI frameworks guide AI ethical and governance principles, with existing sector-specific regulations addressing AI risks.



Spain creates Europe's first AI supervisory agency and actively participates in EU AI Act negotiations.



Switzerland's National AI Strategy sets out guidelines for the use of AI, and aims to finalize an AI regulatory proposal in 2025.



Draft laws and guidelines are under consideration in Taiwan, with sector-specific initiatives already in place.

Taiwan city

United Kingdom

The UK prioritizes a flexible framework over comprehensive regulation and emphasizes sector-specific laws.

London hero image

United Nations

The UN's new draft resolution on AI encourages Member States to implement national regulatory and governance approaches for a global consensus on safe, secure and trustworthy AI systems.

United Nations

United States

The US relies on existing federal laws and guidelines to regulate AI but aims to introduce AI legislation and a federal regulation authority.

New York city photo


Tim Hickman
Erin Hanson
New York
Dr. Sylvia Lorenz

AI Watch: Global regulatory tracker - Norway

Position paper informs Norwegian approach to AI, with sector-specific legislative amendments to regulate developments in AI.

8 min read

Laws/Regulations directly regulating AI (the “AI Regulations”)

Currently, there are no specific laws, statutory rules, or regulations in Norway that directly regulate AI. Norway is not expected to enact its own comprehensive AI legislation, with the exception of the EU AI Act, which is expected to become Norwegian law in the same manner as for all European Economic Area (EEA) Member States. 

In addition, the Norwegian government continues to consider whether any other existing legal framework should also be amended (as necessary) to meet any technological developments.1

Norwegian laws are largely technology-neutral and flexible, thereby indirectly encompassing AI within a significant portion of its legal framework

Status of the AI Regulations

As noted above, there are currently no specific laws or regulations in Norway that directly regulate AI. 

However, as Norway is an EEA country, the EU AI Act is expected to eventually be implemented as Norwegian law, even though no formal decision or approval has been made. With respect to the implementation of the EU AI Act in Norway, the current status can be followed on the Norwegian government website (only in Norwegian). During the period after the EU AI Act has entered into force in the EU, but before the EU AI Act is implemented into Norwegian law, the EU AI Act may still apply to Norwegian companies due to its extraterritorial provisions.2

In 2021, the Norwegian government published the Norwegian Position Paper on the European Commission’s Proposal for a Regulation of the European Parliament and of the Council Laying Down Harmonized Rules on AI (the “Position Paper”), which sets out the government’s approach on AI. The paper also establishes their support for the EU AI Act (including its definition of AI, risk-based approaches, classification of high-risk AI systems, etc.), their concerns regarding the relationship between the EU AI Act and other legal frameworks, consequences for SMEs, their establishment of the Regulatory Sandbox (the “Sandbox”) by the Norwegian Data Protection Authority (Datatilsynet) and foreseen governance structures.3

Other laws affecting AI

There are various laws that do not directly seek to regulate AI but may affect the development or use of AI in Norway. Norwegian regulations are largely technology-neutral, implying their applicability irrespective of the technology in use (also encompassing AI).

A non-exhaustive list of key examples includes:

  • The Norwegian constitution, especially Chapter E (human rights) 
  • The Equality and Discrimination Act
  • The Working Environment Act
  • The Transparency Act (which is, among other things, intended to promote businesses’ respect for fundamental human rights in connection with the production of goods and provision of services)
  • The Personal Data Act (which includes the GDPR)
  • Product liability and product safety rules
  • The Marketing Control Act, Consumer Purchase Act and Digital Services Act. For instance, advertising or marketing should not be misleading or appear as something other than what it is, which includes situations where AI has been employed in the marketing process. Consumer laws also include requirements for providers of products or services that include AI
  • Intellectual property laws may affect several aspects of AI development and use. For instance, the Norwegian Copyright Act can be invoked in cases involving generative AI training or use, and text and data mining
  • The Law Enforcement Directive and other sector-specific regulations such as the Health Register Act, the Police Register Act and the Police Register Regulatio
  • During the COVID-19 crisis, a temporary regulation that authorized fully automatic processing was added to the National Insurance Act. The statute was later added to the Labor and Welfare administration Act on December 4, 2020
  • The Law Commission made recommendations to the Archival Act and Public Administration Act, which aim to provide transparency and accountability in public administration systems where AI is used

Definition of “AI”

As noted above, there are currently no specific laws or policies in Norway that directly regulate AI. Accordingly, no definition of AI is currently recognized through Norwegian national legislation. 

However, in January 2020, the Norwegian government presented its National AI Strategy, which adopts the definition set out by the European Commission’s High Level Expert Group on AI, which is “AI systems act in the physical or digital dimension by perceiving their environment, processing and interpreting information, and deciding the best action(s) to take to achieve the given goal. Some AI systems can adapt their behavior by analyzing how the environment is affected by their previous action.”4

The Norwegian government also supports the definition of AI proposed by the EU Commission under the EU AI Act.5

Territorial scope 

As noted above, there are currently no specific laws or regulations in Norway that directly regulate AI. Accordingly, there is no specific territorial scope at this stage.

Sectoral scope 

As noted above, there are currently no specific laws or regulations in Norway that directly regulate AI. Accordingly, there is no specific sectoral scope at this stage. However:

  • Health sector: A proposal to enable the Health Data Program and the Health Analysis Data platform to utilize AI took effect in January 2021. In June 2021, the Norwegian parliament also amended the Health Personnel Act and the Health Records Act to allow data access to clinical decision support based on AI6
  • As explained in section 3 above, the Law Commission made recommendations to the Archival Act and Public Administration Act that relate to public sector administrative proceedings and the use of AI in public administration. No formal proposal from the government has yet been proposed7

Compliance roles 

As noted above, there are currently no specific laws or regulations in Norway that directly regulate AI. Accordingly, there are currently no specific or unique obligations imposed on developers, users, operators and/or deployers of AI systems.  

The 2020 National AI Strategy focuses on all actors along the AI value chain, as well as on society as a whole. The strategy papers emphasize the responsibilities of AI users and operators (which are not defined), but also address the interests of affected persons (and affected sectors).8

Core issues that the AI Regulations seek to address

As noted above, there are currently no specific laws or regulations in Norway that directly regulate AI. Nevertheless, the National AI Strategy highlights a number of policy initiatives:9

  • Expanding the offer of education programs and workplace trainings in the field of AI in order to create a solid basis of digital skills and capabilities
  • Strengthening Norwegian research in AI
  • Enhancing the innovation capacity in AI in both the private and public sectors
  • Outlining ethical principles for AI in order to allow fair, reliable and trustworthy AI-related developments
  • Establishing digitalization-friendly regulations to define the legislative framework in which AI developments take place
  • Constructing a strong data infrastructure ensuring open data and data sharing across sectors and business areas. Dedicated opportunities for language data resources are established through the Norwegian language bank at the National Library
  • Deploying a telecommunication infrastructure that provides high-capacity connectivity and computing power, and that ensures security in AI-based systems

In 2020, the Datatilsynet also established the Sandbox, to allow for testing, developing and monitoring AI concepts in a protected environment, and to promote the development of ethical and responsible AI solutions, especially with respect to privacy. As of January 2024, the Datatilsynet is in the fifth round of the Sandbox, with the most recent round selecting four new projects in Generative AI.10

Risk categorization

As noted above, there are currently no specific laws or regulations in Norway that directly regulate AI. However, the Position Paper supports the risk-based approach of the EU AI Act.11

Key compliance requirements 

As noted above, there are currently no specific laws or regulations in Norway that directly regulate AI. However, there are certain compliance requirements for the use of automated systems (which may include AI) with regards to the health sector and the Labor and Welfare Administration act (as explained in sections 3 and 6 above).


The Norwegian government foresees designating a national supervisory authority, in accordance with the EU AI Act proposal. Norway, as an EEA Member State, should be represented in the European Artificial Intelligence Board (EAIB) to be established in accordance with Title VI, Chapter I of the proposal, equivalent to their participation in the European Data Protection Board.12

It has not yet been decided which regulatory body will remain the main regulator of AI, and several bodies have expressed interest. A potential candidate may be Datatilsynet, which: (i) is already running the Sandbox as explained in section 8 above;13 (ii) has published a strategy for its internal and external work with AI; and (iii) aims to contribute to having a coordinated and unified approach to AI both internally to its own operations and externally toward society as a whole.14

However, Datatilsynet’s competence is currently related to processing of personal data and not specifically focused on AI or technology in general.

Enforcement powers and penalties 

As noted above, there are currently no specific laws or regulations in Norway that directly regulate AI. Accordingly, it is currently unclear what enforcement powers or penalties the Datatilsynet may impose upon breaches.

1 See the National AI Strategy here, page 21.
2  See the AI Act article 2 (b) and (c). For example, if a provider in Norway is "putting into service" AI systems, or AI models, in the EU, or if a provider or deployer in Norway, where the output from the AI system, is used in the EU, the regulation will apply.
See the Position Paper here
See the National AI Strategy here, page 9
See the Position Paper here.
See here.
See the National AI Strategy here, page 26.
See the National AI Strategy here.
See the National AI Strategy here
See here.
See the Position Paper here.
See the Position Paper here.
See here
See here.

White & Case means the international legal practice comprising White & Case LLP, a New York State registered limited liability partnership, White & Case LLP, a limited liability partnership incorporated under English law and all other affiliated partnerships, companies and entities.

This article is prepared for the general information of interested persons. It is not, and does not attempt to be, comprehensive in nature. Due to the general nature of its content, it should not be regarded as legal advice.

© 2024 White & Case LLP

Jeffrey Shin (Trainee Solicitor, White & Case, London) contributed to this publication.

Wiersholm contributors

Rune Opdahl

Rune Opdahl
Partner, Wiersholm
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Fredrik Wiker

Fredrik Wiker
Associate, Wiersholm
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Ines Tafjord

Ines Tafjord
Associate, Wiersholm
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