Background Artificial intelligence (AI) is developing more rapidly than the laws designed to govern it. In response, the EU and the UK have chosen different regulatory paths. The EU has introduced Regulation (EU) 2024/1689 (the EU AI Act), a detailed, cross-sector framework built around legally binding obligations and a structured risk-based model, as now amended by Regulation (EU) 2026/1744, the Digital Omnibus on AI. The UK has taken a more flexible approach, relying on existing regulators and high-level principles to guide the responsible development and use of AI. These differing strategies present practical challenges for businesses operating across both markets, who are faced with navigating differences in scope, compliance expectations and enforcement risk. Understanding how the two regimes compare is essential for identifying areas of alignment, establishing effective governance structures, and informing procurement, product development, and broader market strategy. This Practice Note explains and compares side-by-side the core features of each regime. What’s happening in the UK? The 2023 AI White Paper and government response endorsed five cross-sector principles (safety/security/robustness; transparency/explainability; fairness; accountability/governance;