Before regulating, planning is essential: leading countries in AI are betting on national strategies to guarantee sovereignty and competitiveness.
*By Francisco Camargo
Now that the regulation of artificial intelligence is being discussed in Brazil, it is interesting to examine what is already being done in other countries, whether to copy them or to deviate from their approaches.
How does Fabio Gabliardi Cozman evaluate it?1,"Very restrictive regulations can hinder local innovation, leading to the need to import technologies."
We have thus described the paths taken by the United States, the United Kingdom, and France.
United States: innovation, innovation, and more innovation.
The United States adopted a decentralized approach, based on already regulated sectorsInstead of a single federal law dedicated to AI, the country opted for... regulate its use through existing laws and guidelines, complemented by initiatives and recommendations from federal agencies.
Current regulatory framework
- There is no specific regulation. but it has strategy and direction with the America's AI Action Plan July 2025.
- Absence of specific federal lawCurrently, there is no comprehensive federal law on AI. Regulation is fragmented, based on sectors regulated and controlled by federal agencies such as health, finance, and transportation, like the... FDA (Food and Drug Administration), the USDOT (Transportation Department) and the FTC (Federal Trade Commission) issue regulations that may involve AI.
- GuidelinesThe federal government issued documents such as the “Blueprint for an AI Bill of Rights” (2022), with principles for guaranteeing basic rights of citizens, such as protection against algorithmic discrimination, data privacy, and explainability;
- Research and ethics: the NIST (National Institute of Standards and Technology) proposes voluntary frameworks for the responsible development of AI, focusing on safety, reliability, transparency, and fairness.
Challenges and perspectives
You United States They prioritize the promotion of innovationfearing that restrictive regulation could stifle startups and technology companies.
United Kingdom: Flexibility and self-regulation
O United Kingdom wants to position itself as global leader in AIwith an approach regulatory flexiblebased on Principles and proportional to the risk, with emphasis on self-regulation and through collaboration between government, the private sector, and academia.
National strategy
- National AI StrategyIn 2021, the British government launched a detailed strategy to foster ethical research, investment, and implementation of AI. The document prioritizes... responsible innovation, skills development and the creation of a adaptable regulatory environment.
- No white paperA Pro-Innovation Approach to AI RegulationIn 2023, the government proposed regulatory principles for AI centered on security, transparency, fairness, accountability, and contestability, with guidelines adaptable to different sectors. There is no intention to create a regulatory agency for AI.
Regulatory framework
- Regulation by sectorexisting organs, such as the ICO (Information Commissioner's Office), OPSS (Office for Product Safety and Standards) and CMA (Competition and Markets Authority) have important roles in overseeing the use of AI in their respective sectors.
- Focus on proportionalityThe UK approach seeks balance the need for protection of citizens and the promotion of innovation, adjusting the standards according to the risk presented by different AI applications.
Challenges and perspectives
The United Kingdom sees AI regulation as a dynamic processwhich must evolve in parallel with technological advancements. The country seeks a role to influence in creation in global standardsespecially on topics related to security, ethics and international governance.
France: accountability and public investment
France leads Europe in formulating public policies and AI regulations aligning with initiatives such as AI Act, the European Union's artificial intelligence law.
National and European regulatory framework
- France is one of the main proponents of AI Act
- Approach risk-based, classifying AI systems according to the potential for harm which can cause problems, with strict obligations for applications that they consider high-risk, such as biometrics, healthcare, and credit systems.
- National AI Strategy (2018 and 2021): France launched the national strategy to promote the search, The ethical development and the Technological sovereignty in AI, with significant public investments and initiatives for the training of professionals.
- CNIL (Commission Nationale de l'Informatique et des Libertés): body that works to protect personal data and oversee the use of AI, ensuring compliance with the GDPR (European LGPD) and other regulations.
Responsibility
The main concern of France and the accountability of developers, suppliers and users of systems AI.
Challenges
The biggest regulatory complexity Europe is seen on one hand as protecting citizens, and on the other as a huge challenge for the competitiveness of European companies.
France defends robust international standards so as not to lose competitiveness.
In short
The approaches of the three countries are different, with three main models, but what is striking is that all three countries have a... national artificial intelligence strategy and seek Technological sovereignty in AI.
Before regulating AI in Brazil, we should have a national artificial intelligence strategy, based on stimulating innovation and in entrepreneurship, training specialists and in the pursuit of creating global standards, so that Brazil does not lose competitiveness.
However, these global standards They will only be useful if the United States and the China They must join, otherwise the countries that do join will become less competitive.
AI is in its infancy, its growth and innovation are progressing rapidly. It's exponential, we have a minimal idea of its potential, and the US wants to be the leader, in the words of President Donald Trump:
As our global competitors race to exploit these technologies, it is a national security imperative for the United States to achieve and maintain unquestioned and unchallenged global technological dominance. To secure our future, we must harness the full power of American innovation.”
It is interesting in this document, among the fundamentals of American strategy, let's check the first paragraph of Pillar I:
Pillar I: Accelerate AI Innovation
Remove Red Tape and Onerous Regulation
The dynamism of Artificial Intelligence demands dynamic regulation that keeps pace with this growth and does not hinder innovation and entrepreneurship in Brazil.
The best thing for Brazil right now is to have a Strategy Technological Sovereignty in Artificial Intelligencegive emphasis on self-regulation ...and not pass any laws that stifle innovation, but rather monitor what the US and China are doing.
*Francisco Camargo is the Founder and CEO of CLM and Treasurer Director of ABES – Brazilian Association of Software Companies.
Notice: The opinion presented in this article is the responsibility of its author and not of ABES - Brazilian Association of Software Companies
Article originally published on the IT Forum website: https://itforum.com.br/colunas/regulamentacao-ia-outros-paises/
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