EU Tech Chief: U.S. AI Rules Converging With Europe's Despite Rhetoric

The United States and European Union are arriving at similar AI safety guardrails despite sharply different regulatory philosophies, according to the EU's top technology official.

European Commission tech chief Henna Virkkunen told Axios that while the U.S. favors a decentralized approach through state legislation and court decisions rather than comprehensive federal rules like the EU AI Act, both regions are ultimately addressing the same fundamental concerns about advanced AI systems.

Why it matters

The convergence suggests that regardless of political rhetoric about regulatory approaches, powerful AI systems are prompting similar policy responses across Western democracies. Companies operating globally may face comparable compliance requirements even as governments pursue different implementation paths.

Different paths, similar destinations

"We see when it comes to technologies that in the USA the culture is different. So often it's coming via court cases, but often very similar things anyway, very similar concerns," Virkkunen said at this week's G20 innovation summit in Chapel Hill, North Carolina. "I don't see that this is so like black and white."

The Trump administration used the summit to emphasize its opposition to Europe's sweeping regulatory framework. SpaceX CEO Elon Musk told attendees that "new things must be default legal as opposed to default illegal," criticizing the EU's "extraordinarily high" regulation level.

Yet even without federal AI legislation, Washington is actively shaping how companies develop advanced models through executive actions, voluntary frameworks, and national security restrictions. The administration has developed a voluntary pre-release review process for some advanced AI models, potentially giving government officials up to 30 days of access before public deployment. OpenAI CEO Sam Altman confirmed this week that the administration reviewed the company's Astra model under this framework.

EU seeks simplification

Virkkunen acknowledged that the EU needs to streamline its regulatory environment, saying it's important to make the region "easier, simpler, faster" for businesses. ChatGPT now officially faces strict requirements under the Digital Services Act.

The European Commission is developing a framework for pre-deployment testing and trusted partner access, an area where both the U.S. and EU are working through similar policy questions. "We are continuing to discuss also under G7, especially with our partners, how we should work on this topic," Virkkunen said.

The regulatory reality

While the U.S. lacks comprehensive federal AI rules, American states are advancing their own regulations, and product changes are being forced on companies through litigation. This patchwork approach may ultimately create compliance burdens comparable to Europe's unified framework.

The details were first reported by Axios.