The UK wants to do its ‘own thing’ on AI regulation, suggesting a divergence from U.S. and EU
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LONDON — The U.K. says it wants to do its “own thing” when it comes to regulating artificial intelligence, hinting at a possible divergence from approaches taken by its main Western peers.
“It’s really important that we as the U.K. do our own thing when it comes to regulation,” Feryal Clark, Britain’s minister for AI and digital government, told CNBC in an interview that aired Tuesday.
She added the government already has a “good relationship” with AI companies like OpenAI and Google DeepMind, which have voluntarily opened their models up to the government for safety testing purposes.
“It’s really important that we bake in that safety right at the beginning when models are being developed … and that’s why we’ll be working with the sector on any safety measures that come forward,” Clark added.
Her comments echoed remarks from Prime Minister Keir Starmer on Monday that Britain has “freedom now in relation to the regulation to do it in a way that we think is best for the U.K.” after Brexit.
“You’ve got different models around the world, you’ve got the EU approach and the U.S. approach – but we have the ability to choose the one that we think is in our best interest and we intend to do so,” Starmer said in response to a reporter’s question after announcing a 50-point plan to make the U.K. a global leader in AI.
Divergence from the U.S., EU
So far, Britain has refrained from introducing formal laws to regulate AI, instead deferring to individual regulatory bodies to enforce existing rules on businesses when it comes to the development and use of AI.
This is different from the EU, which has introduced comprehensive, pan-European legislation aimed at harmonizing rules for the technology across the bloc taking a risk-based approach to regulation.
The U.S., meanwhile, lacks any AI regulation whatsoever at a federal level and has instead adopted a patchwork of regulatory frameworks at the state and local level.
During Starmer’s election campaign last year, the Labour Party committed in its manifesto to introducing regulation focusing on so-called “frontier” AI models — referring to large language models like OpenAI’s GPT.
However, so far, the U.K. is yet to confirm details on proposed AI safety legislation, instead saying it will consult with the industry before proposing formal rules.
“We will be working with the sector to develop that and bring that forward in line with what we said in our manifesto,” Clark told CNBC.
Chris Mooney, partner and head of commercial at London-based law firm Marriott Harrison, told CNBC that the U.K. is taking a “wait and see” approach to AI regulation even as the EU is forging ahead with its AI Act.
“While the U.K. government says it has taken a ‘pro-innovation’ approach to AI regulation, our experience of working with clients is that they find the current position uncertain and, therefore, unsatisfactory,” Mooney told CNBC via email.
One area Starmer’s government has spoken up on reforming rules for AI has been around copyright.
Late last year, the U.K. opened a consultation reviewing the country’s copyright framework to assess possible exceptions to existing rules for AI developers using artists and media publishers’ works to train their models.
Businesses left uncertain
Sachin Dev Duggal, CEO of London-headquartered AI startup Builder.ai, told CNBC that, although the government’s AI action plan “shows ambition,” proceeding without clear rules is “borderline reckless.”
“We’ve already missed crucial regulatory windows twice — first with cloud computing and then with social media,” Duggal said. “We cannot afford to make the same mistake with AI, where the stakes are exponentially higher.”
“The U.K.’s data is our crown jewel; it should be leveraged to build sovereign AI capabilities and create British success stories, not simply fuel overseas algorithms that we can’t effectively regulate or control,” he added.
Details of Labour’s plans for AI legislation were initially expected to appear in King Charles III’s speech opening U.K. Parliament last year.
However, the government only committed to establishing “appropriate legislation” on the most powerful AI models.
“The U.K. government needs to provide clarity here,” John Buyers, international head of AI at law firm Osborne Clarke, told CNBC, adding he’s learned from sources that a consultation for formal AI safety laws is “waiting to be released.”
“By issuing consultations and plans on a piecemeal basis, the U.K. has missed the opportunity to provide a holistic view of where its AI economy is heading,” he said, adding that failure to disclose details of new AI safety laws would lead to investor uncertainty.
Still, some figures in the U.K. tech scene think that a more relaxed, flexible approach to regulating AI may be the right one.
“From recent discussions with the government, it is clear that considerable efforts are underway on AI safeguards,” Russ Shaw, founder of advocacy group Tech London Advocates, told CNBC.
He added that the U.K is well positioned to adopt a “third way” on AI safety and regulation — “sector-specific” regulations that rules to different industries like financial services and health care.
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The Federal Trade Commission asked a judge in Seattle to delay the start of its trial accusing Amazon of duping consumers into signing up for its Prime program, citing resource constraints.
Attorneys for the FTC made the request during a status hearing on Wednesday before Judge John Chun in the U.S. District Court for the Western District of Washington. Chun had set a Sept. 22 start date for the trial.
Jonathan Cohen, an attorney for the FTC, asked Chun for a two-month continuance on the case due to staffing and budgetary shortfalls.
The FTC’s request comes amid a push by the Trump administration’s Department of Government Efficiency to reduce spending. DOGE, which is led by tech baron Elon Musk, has slashed the federal government’s workforce by more than 62,000 workers in February alone.
“We have lost employees in the agency, in our division and on our case team,” Cohen said.
Chun asked Cohen how the FTC’s situation “will be different in two months” if the agency is “in crisis now, as far as resources.” Cohen responded by saying that he “cannot guarantee if things won’t be even worse.” He pointed to the possibility that the FTC may have to move to another office “unexpectedly,” which could hamper its ability to prepare for the trial.
“But there’s a lot of reason to believe … we may have been through the brunt of it, at least for a little while,” Cohen said.
John Hueston, an attorney for Amazon, disputed Cohen’s request to push back the trial date.
“There has been no showing on this call that the government does not have the resources to proceed to trial with the trial date as presently set,” Hueston said. “What I heard is that they’ve got the whole trial team still intact. Maybe there’s going to be an office move. And by the way, both in government and private sector, I’ve never heard of an office move being more than a few days disruptive.”
The FTC sued Amazon in June 2023, alleging that the online retailer was deceiving millions of customers into signing up for its Prime program and sabotaging their attempts to cancel it. Amazon has denied any wrongdoing, calling the FTC’s claims “wrong on the facts and the law.”
“Amazon tricked and trapped people into recurring subscriptions without their consent, not only frustrating users but also costing them significant money,” former FTC Chair Lina Khan said at the time.
The FTC brought a separate case against Amazon in September 2023 accusing it of wielding an illegal monopoly. The agency alleged that Amazon prevents sellers from offering cheaper prices elsewhere through its anti-discounting measures. That case is set to go to trial in October 2026.
In the time since the FTC filed its cases, Khan has been replaced as the head of the FTC by Trump appointee Andrew Ferguson. Tech companies, which are the target of several regulatory agencies, have sought to curry favor with Trump, including Amazon founder and executive chairman Jeff Bezos. He attended President Donald Trump’s inauguration in January, and Amazon was among several tech companies to donate $1 million to Trump’s inauguration committee.
WATCH: Trump FTC Chair tells CEOs it will crack down on conduct or mergers that hurt Americans
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