AI regulation guide
AI regulation for managers: the 2026 guide.
The EU AI Act after the Digital Omnibus, US federal and state AI laws, Korea, China and the international instruments, and the five duties they share, with dates and what to do about each.
In short: there is no single AI law. A manager in 2026 deals with the EU AI Act, which applies in stages through 2028;1,2 a patchwork of US state laws under a federal government that wants to preempt them;3 and national laws and labeling rules in Asia.4,5 Almost all of them ask for the same five things: tell people when AI affects them, assess the impact before consequential use, document the system, keep a person accountable for decisions that matter, and report serious incidents. Build those five once and each new law becomes a mapping exercise. This guide is educational, not legal advice.
The five duties almost every AI law shares
Read side by side, the instruments differ in reach and penalties but converge on the same obligations. The table shows where each duty appears in the laws covered in this guide.
| Duty | Where it appears | What it looks like in practice |
|---|---|---|
| Notice to affected people | EU AI Act Article 50;1 California automated decision rules;6 Colorado SB 26-189;7 Illinois HB 3773;8 Connecticut Public Act 26-15 (hiring tools);9 South Korea AI Basic Act4 | A plain statement that AI is used, before or at the point of use |
| Impact or risk assessment | EU high-risk rules;1 South Korea (high-impact AI, as a duty to make efforts);4 California privacy agency risk assessments6 | A documented assessment for each consequential system, kept current |
| Documentation | EU AI Act (providers and general-purpose models);1 Colorado developer documentation7 | Technical documentation, instructions for use, records of testing |
| Human oversight and review | EU high-risk rules;1 Colorado;7 California opt-out and access;6 GDPR Article 2210 | A real person who can review, explain and override |
| Incident reporting | EU AI Act Article 73;1 California SB 53;11 New York RAISE Act12 | A procedure with severity levels and legal clocks |
The dates for every instrument below are kept in one place in the AI regulatory calendar.
The European Union: the AI Act after the Digital Omnibus
The AI Act (Regulation (EU) 2024/1689) entered into force on August 1, 2024 and applies in stages.1 It reaches beyond Europe: providers that place AI on the EU market, deployers in the EU, and providers and deployers elsewhere whose system output is used in the EU.1 Most organizations are deployers, and deployers carry real obligations.
- Applying now: prohibited practices (since February 2, 2025), the AI-literacy duty in Article 4, obligations for providers of general-purpose AI models (since August 2, 2025), and transparency duties under Article 50 (from August 2, 2026).1
- Moved by the Digital Omnibus (Regulation (EU) 2026/1744, in force since July 27, 2026): stand-alone high-risk systems such as those used in employment, credit and access to essential services from December 2, 2027; AI in regulated products from August 2, 2028; machine-readable marking for systems already on the market from December 2, 2026, the same date a new prohibition on generating non-consensual intimate imagery and child sexual abuse material applies.2
- Penalties reach up to 35 million euros or 7 percent of global turnover for prohibited practices.1
Further reading: the EU AI Act after the Digital Omnibus, what to ask general-purpose model providers, AI literacy after the omnibus and the June record of the provisional delay agreement.
What a deployer owes under the EU AI Act
| If you use... | Your main duties | When |
|---|---|---|
| A chatbot or assistant that talks to people | Tell people they are interacting with AI | From August 2, 20261 |
| Generative AI that produces realistic media or public-interest text | Disclose deepfakes and AI-generated text on matters of public interest | From August 2, 20261 |
| A stand-alone high-risk system (for example in hiring or credit) | Use it as instructed, assign human oversight, monitor it, keep logs, inform affected workers and people, report serious incidents | From December 2, 20271,2 |
| Any AI system, as an organization | Take measures to support the AI literacy of staff and others using AI on your behalf | Since February 2, 2025 (amended July 2026)1,2 |
If you rebrand a high-risk system or substantially modify it, the Act's value-chain rules can make you its provider, with the provider's heavier duties.1
The United States: federal posture, state rules
There is no comprehensive federal AI statute. Executive Order 14365 of December 11, 2025 set out to build a national framework, created a litigation task force to challenge state laws the administration considers burdensome and tied some federal funding to them;3 on March 20, 2026 the White House sent Congress legislative recommendations for a federal standard that would preempt such laws.13 Neither preempts anything by itself: the Senate voted 99 to 1 in July 2025 against a moratorium on state AI laws,14 and state laws remain enforceable until Congress or a court says otherwise.
| State or city | Instrument | From | Core duty |
|---|---|---|---|
| New York City | Local Law 144 | 2023 | Independent bias audit and notice for automated employment decision tools15 |
| California | Civil Rights Council rules | October 1, 2025 | Automated-decision discrimination under FEHA; four years of records16 |
| Texas | HB 149 (TRAIGA) | January 1, 2026 | Prohibited uses; disclosure by agencies and in health care; defense for following a recognized framework such as the NIST AI RMF17 |
| California | SB 53 | January 1, 2026 | Frontier developers publish safety frameworks and report critical incidents11 |
| Illinois | HB 3773 | January 1, 2026 | Notice when AI is used in employment decisions; no discriminatory use8 |
| California | AI Transparency Act (SB 942, AB 853) | August 2, 2026 | Provenance disclosures in AI images, video and audio from large providers18,19 |
| Connecticut | Public Act 26-15 | October 1, 2026, in stages to January 1, 2028 | Key-terms notice before charging for consumer AI subscriptions and whistleblower protections at frontier developers; AI companion rules from January 1, 2027; notice to applicants and employees about automated employment decision technology from October 1, 20279 |
| California | Privacy agency ADMT rules | January 1, 2027 | Pre-use notice, opt-out and access for significant automated decisions6 |
| Colorado | SB 26-189 | January 1, 2027 | Notice, explanation after adverse outcomes, correction and human review7 |
| New York | RAISE Act, as amended | January 1, 2027 | Frontier developers report critical safety incidents within 72 hours12 |
Connecticut's Public Act 26-15 is one law with several start dates: on October 1, 2026 its first AI sections apply (a written key-terms notice and the consumer's acceptance before a provider charges for an AI subscription, whistleblower protections at frontier model developers, and a statement in WARN layoff notices of whether the layoffs relate to AI); rules for AI companions follow on January 1, 2027; employers must tell applicants and employees when they interact with an automated employment-related decision technology, with written notice before a decision in which its output is a substantial factor, from October 1, 2027; and duties toward minors on covered online platforms apply from January 1, 2028.9 Read the effective date of each section, not the headline.
Further reading: US AI law in 2026, state by state, what Executive Order 14365 does, the White House framework, the January 1, 2026 laws, Colorado SB 26-189, California's automated decision rules, the California AI Transparency Act and the October 2026 member briefing on Connecticut.
Asia and international instruments
- South Korea's AI Basic Act has applied since January 22, 2026: duties for high-impact AI, labels on generative output, and a domestic representative for large foreign providers, with fines (up to 30 million won) expected only after a grace period of at least one year.430 Its impact assessment is a duty to make efforts rather than a strict requirement, while the explanation and user-protection duties for high-impact AI are mandatory.4 See the Korea briefing.
- China regulates through targeted measures; its rules on labeling AI-generated content took effect on September 1, 2025.5
- Japan's AI Promotion Act (May 2025) sets up a strategy headquarters and a basic plan without penalties;20 Singapore publishes voluntary model frameworks, including one for agentic AI in January 202621 (see the Singapore briefing).
- The Council of Europe Framework Convention, opened for signature in September 2024, is the first binding international AI treaty;22 summit declarations such as New Delhi's (February 2026) bind no one but show where governments agree.23 See the one-page global map.
Decisions about people: the most litigated ground
Hiring, lending, insurance and access to services are where AI law is most active and where disputes reach court. In Europe, the SCHUFA and Dun & Bradstreet judgments hold that a score can itself be an automated decision and that people are owed an intelligible explanation.24,25 In the United States, Mobley v. Workday tests whether the vendor of a screening tool can be liable alongside the employer,26 and the 1978 four-fifths rule remains the first screen for adverse impact.27 Further reading: the SCHUFA judgment, Mobley v. Workday, fairness testing and the four-fifths rule and the Rite Aid order.
Existing law still applies
New AI statutes sit on top of laws that already govern decisions, data and claims. Privacy law (the GDPR in Europe, the CCPA and its regulations in California) governs the personal data AI systems use.6,10 Anti-discrimination law governs hiring, lending and housing decisions whether or not a person or a model made them,16 and consumer protection law governs what companies tell customers: the FTC's order against Rite Aid (proposed in December 2023, entered in March 2024)28 and a Canadian tribunal's 2024 ruling that Air Canada was bound by what its chatbot said29 both rested on existing law, not on an AI statute. Our briefing on three documented AI failures covers the Air Canada case.
How to run AI compliance without a separate program per law
- Inventory. Every AI system, who it affects, where those people are, and which decisions it makes or influences.
- Jurisdiction register. For each system, the instruments that apply, the duty that matters most, and the next date. Review it quarterly.
- One control set to the strictest rule. One notice template, one impact assessment, one documentation set, one human-review and appeal process, adapted per jurisdiction.
- Vendor terms. Documentation, logs, cooperation with regulators and incident notice in every AI contract; see five clauses that decide whether an AI contract protects you.
- Incident procedure. Severity levels and the legal clocks; see AI incident response.
- Watch list. A monthly look at the regulatory calendar and the Monday briefings, with a named owner.
Law and regulation for managers is taught in Module 6 of the AIMP AI management certification, alongside the governance frameworks in Module 5 that supply most of the evidence regulators ask for. For the governance side of this guide, see AI governance for managers.
Questions
Does the EU AI Act apply to US companies?
Yes, in many cases. It applies to providers that place AI systems on the EU market and to providers and deployers outside the EU whose AI output is used in the EU, as well as to deployers established in the EU.
When does the EU AI Act apply?
In stages: prohibited practices and AI literacy from February 2, 2025; general-purpose model duties from August 2, 2025; transparency duties from August 2, 2026; stand-alone high-risk systems from December 2, 2027 and AI in regulated products from August 2, 2028, after the 2026 Digital Omnibus.
Is there a federal AI law in the United States?
No comprehensive one. Federal policy works through executive orders and agency guidance, and the White House has asked Congress for a national framework that would preempt some state laws. Until Congress acts, state AI laws such as those in Texas, California, Colorado, Illinois, Connecticut and New York apply.
Do I have to tell customers I use AI?
Often, yes. The EU AI Act requires notice when people interact with an AI system from August 2, 2026, and several US states require notice before or when AI is used in significant or consequential decisions, including California from January 1, 2027 and Colorado under SB 26-189.
Is this guide legal advice?
No. It explains what the main AI laws say and what managers commonly do about them. Confirm how they apply to your organization with counsel.
Sources (checked October 17, 2026)
- Regulation (EU) 2024/1689 (Artificial Intelligence Act), Official Journal of the European Union (opens in a new tab) eur-lex.europa.eu
- Regulation (EU) 2026/1744 (Digital Omnibus on AI), Official Journal of the European Union, July 24, 2026 (opens in a new tab) eur-lex.europa.eu
- Federal Register, Executive Order 14365, "Ensuring a National Policy Framework for Artificial Intelligence" (December 11, 2025), 90 FR 58499 (opens in a new tab) govinfo.gov
- Cooley, "South Korea's AI Basic Act: Overview and Key Takeaways" (January 27, 2026) (opens in a new tab) cooley.com
- Loeb & Loeb, "China's AI Labeling Measures and Mandatory National Standards Take Effect September 1" (March 2025) (opens in a new tab) loeb.com
- California Privacy Protection Agency, regulations on automated decision-making technology, risk assessments and cybersecurity audits (approved September 23, 2025) (opens in a new tab) cppa.ca.gov
- JD Supra (McDermott Will & Schulte), "Colorado AI law in flux: Comprehensive replacement bill signed after federal court blocks predecessor's enforcement" (May 28, 2026) (opens in a new tab) jdsupra.com
- Morgan Lewis, "Illinois Passes New Law to Address AI in the Workplace" (September 2024), on HB 3773 (opens in a new tab) morganlewis.com
- Connecticut General Assembly, Public Act 26-15, Substitute Senate Bill No. 5, "An Act Concerning Online Safety" (2026 session) (opens in a new tab) cga.ct.gov
- Regulation (EU) 2016/679 (General Data Protection Regulation), Article 22 (opens in a new tab) eur-lex.europa.eu
- California Legislative Information, SB 53 (2025), Transparency in Frontier Artificial Intelligence Act (opens in a new tab) leginfo.legislature.ca.gov
- Cooley, "New York's Frontier AI Law Gets a California Makeover, With Some Key Differences" (March 31, 2026) (opens in a new tab) cooley.com
- Holland & Knight, "White House Releases a National Policy Framework for Artificial Intelligence" (March 27, 2026) (opens in a new tab) hklaw.com
- U.S. Senate Committee on Commerce, "Senate Strikes AI Moratorium from Budget Reconciliation Bill in Overwhelming 99-1 Vote" (July 1, 2025) (opens in a new tab) commerce.senate.gov
- NYC Department of Consumer and Worker Protection, Automated Employment Decision Tools (Local Law 144) (opens in a new tab) nyc.gov
- Paul Hastings, "New California Regulations on Employers' Use of AI to Make Decisions Go Into Effect Oct. 1, 2025" (August 12, 2025) (opens in a new tab) paulhastings.com
- Texas Legislature, HB 149 (89th Legislature), Texas Responsible Artificial Intelligence Governance Act, enrolled text (opens in a new tab) capitol.texas.gov
- California Legislative Information, AB 853 (2025), amending the California AI Transparency Act (SB 942) (opens in a new tab) leginfo.legislature.ca.gov
- Morgan Lewis, "New California AI Disclosure Rules Become Operative" (August 3, 2026) (opens in a new tab) morganlewis.com
- White & Case, "Japan's first AI legislation becomes law" (2025) (opens in a new tab) whitecase.com
- Infocomm Media Development Authority (Singapore), "Factsheet: Model AI Governance Framework for Agentic AI" (January 22, 2026) (opens in a new tab) imda.gov.sg
- Council of Europe, "Council of Europe opens first ever global treaty on AI for signature" (September 5, 2024) (opens in a new tab) coe.int
- Ministry of Electronics and Information Technology (Government of India), Digital India press release, "More countries join the New Delhi Declaration on AI Impact" (February 2026) (opens in a new tab) digitalindia.gov.in
- Court of Justice of the European Union, SCHUFA Holding (C-634/21), judgment of December 7, 2023 (opens in a new tab) curia.europa.eu
- Society for Computers and Law, "CJEU rules that data subjects are entitled to explanations of automated credit decisions" (2025), on Dun & Bradstreet Austria (C-203/22), judgment of February 27, 2025 (opens in a new tab) scl.org
- Seyfarth Shaw, "Mobley v. Workday: Court Holds AI Service Providers Could Be Directly Liable for Employment Discrimination Under Agent Theory" (July 2024) (opens in a new tab) seyfarth.com
- 29 CFR Part 1607, Uniform Guidelines on Employee Selection Procedures (1978), electronic Code of Federal Regulations (opens in a new tab) ecfr.gov
- Federal Trade Commission, case page "Rite Aid Corporation, FTC v." (complaint and proposed stipulated order filed December 19, 2023; stipulated order for permanent injunction filed March 8, 2024) (opens in a new tab) ftc.gov
- Moffatt v. Air Canada, 2024 BCCRT 149 (British Columbia Civil Resolution Tribunal, February 14, 2024) (opens in a new tab) canlii.org
- Shin & Kim, "AI Basic Act Update: Enforcement and Key Implications" (February 11, 2026) (opens in a new tab) shinkim.com
IAIM guides are educational and are not legal advice. Every source above was used in the briefings this guide draws on.
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