British businesses told: Compliance with EU AI law will satisfy UK guidance With the UK launching its guidance for governing AI development and deployment last week, legal experts are warning that most organizations will look to the proposed EU AI Act as a means of complying with both regimes. The AI Act, which proposes a tiered approach to bans, restrictions, and safeguards in the introduction of AI …
All I read were weasel words, meeting the EU reqs “should” or “would probably” be ok in the UK. That doth butter no parsnip. A business would imo be foolish to make the assumption.
It could be fixed with a something like a statutory legal fiction along the lines of ‘businesses that meet the EU reqs are deemed to meet the UK reqs’. But that wasn’t the point of Brexit now, was it?
@I am David Jones
"It could be fixed with a something like a statutory legal fiction along the lines of ‘businesses that meet the EU reqs are deemed to meet the UK reqs’. But that wasn’t the point of Brexit now, was it?"
Why? The EU wants more regulation, the UK less, what is wrong with that and that is the point of brexit. The UK doesnt have to do what the other government away from the country wants.
But businesses that sell into the EU or offer services to it do have to follow EU law though.
So the UK government gets to enact performative divergence and trumpet about how light touch the UK is (as if that were a good thing) but to UK businesses it means absolutely nothing.
Was that the point of brexit?
@AC
"But businesses that sell into the EU or offer services to it do have to follow EU law though."
That is not amazing. If you sell into any country your product/service must follow the laws of the importer. That was something I repeatedly stated back when people were arguing leave/remain.
"So the UK government gets to enact performative divergence and trumpet about how light touch the UK is (as if that were a good thing) but to UK businesses it means absolutely nothing."
Why does it mean nothing? Lets say the EU regulates so hard that development moves out of the EU. The UK doesnt need to change anything to support the businesses now pivoting to other countries.
"Was that the point of brexit?"
To not have to apply foreign laws domestically. Business selling to the EU must meet EU requirements on said exports just as they meet the differing requirements to any country their product exports to. But domestically they are not so restricted.
Lets say the EU regulates so hard that development moves out of the EU. The UK doesnt need to change anything to support the businesses now pivoting to other countries.
Hardly post-Brexit UK being the master of its own destiny, rather just waiting and hoping that EU countries fumble the ball.
Business selling to the EU must meet EU requirements on said exports just as they meet the differing requirements to any country their product exports to. But domestically they are not so restricted.
Why would they have two herds of cattle and treat one worse for domestic consumption, build two models of the same car with one being more dangerous for domestic buyers, or develop two sets of AIs with one lacking guardrails and selling all data belonging to domestic users? It makes no sense and it's cheaper just for UK businesses just to follow the higher standard (whoever has it, although given the direction of travel it's probably the EU) and sell to both markets.
@AC
"Hardly post-Brexit UK being the master of its own destiny, rather just waiting and hoping that EU countries fumble the ball."
Eh? Nothing to do with that at all. Any business wishing to do business with another country must make sure their exports meet the legal requirements of the importing country. Doesnt matter if it is UK, US, EU, China or anywhere. Post brexit we dont need to apply EU requirements domestically. Its pretty simple and actually does point to "the UK being the master of its own destiny" if you wish to put it like that.
"Why would they have two herds of cattle and treat one worse for domestic consumption"
Its its only for domestic consumption or export to somewhere other than the EU, why apply EU requirements? Why would the smaller domestic providers apply large global business rules for other countries? I also note the huge mistake of saying treat worse or more dangerous, which is to make the flawed assumption that a rule is good because its a rule. A good rule can be good but a rule is not necessarily good.
"It makes no sense and it's cheaper just for UK businesses just to follow the higher standard (whoever has it, although given the direction of travel it's probably the EU) and sell to both markets."
Assuming the trade is with the EU and the domestic market is small enough to prefer export market rules. Also assumes no domestic models that may work better.
Here is an example of rule stupidity. It takes the same amount of energy to boil a kettle (excluding losses from slower boiling). Should the EU decide its a good idea to limit the power of a kettle they are only increasing the amount of time to boil water, not making it more efficient. Add the loss of slower boiling and the rule would be less energy efficient. The UK could ditch said rules and have working kettles for domestic and export to non-stupid countries but export only inefficient ones for the EU if a business so wished.
Putting aside the non-sequitur of comparing kettles to generative AI.
Okay, before we put it aside, let us remark that as energy demands goes up it makes sense to flatten overall demand to allow more appliances to be used at the same time.
Now let's put that aside and go back to the subject.
Any business wishing to do business with another country must make sure their exports meet the legal requirements of the importing country.
I know this, you know this. We agree. No need to debate this any further.
You said:
Lets say the EU regulates so hard that development moves out of the EU. The UK doesnt need to change anything to support the businesses now pivoting to other countries.
To which I replied:
"Hardly post-Brexit UK being the master of its own destiny, rather just waiting and hoping that EU countries fumble the ball."
Do you see now?
Where is the initiative? Where is the UK taking business now from the EU with its laxer laws? I don't see it happening and you didn't suggest it as a possibility. You only suggested that if the EU ever regulates so hard in the future, the UK might be able to gain business. Not the buccaneering post-Brexit UK stealing business from other countries we were sold.
I also note the huge mistake of saying treat worse or more dangerous, which is to make the flawed assumption that a rule is good because its a rule.
Again answered in the same post you replied to:
"It makes no sense and it's cheaper just for UK businesses just to follow the higher standard (whoever has it, although given the direction of travel it's probably the EU) and sell to both markets."
Perhaps there are small businesses which sell innovative jams just to the domestic market. That's fine. But I don't think pre-Brexit UK/EU standards were ever a barrier to that because it was already happening.
Post-Brexit, UK-only standards have created a barrier though:
Post-Brexit food labelling rules to appease DUP will lead to higher prices, says industry
This was bureaucracy entirely of the UK's making and it affects just the GB market.
@AC
"Putting aside the non-sequitur of comparing kettles to generative AI."
The point that I made to correct your assumption that a rule is good because its a rule and everything else is worse.
"Do you see now?"
Yes and my point still being correct. It isnt about the UK waiting for the EU to fumble the ball. Its about not fumbling the ball here to make it a good place for business.
"Where is the initiative? Where is the UK taking business now from the EU with its laxer laws? I don't see it happening and you didn't suggest it as a possibility."
It isnt quite limited to the UK taking business from elsewhere, but allowing development to happen which may not be possible in more restrictive countries. Maybe you dont see it happening but I assumed it as given understanding that the UK would be easier to work with the EU but also any other country in the world including where the EU rules wont let EU business.
"Perhaps there are small businesses which sell innovative jams just to the domestic market. That's fine. But I don't think pre-Brexit UK/EU standards were ever a barrier to that because it was already happening."
Nope. That is to not understand the opportunity costs. The jams thing is funny, I think it was something to do with the EU dictating what could be called jam or something just as stupid. But if you want to know domestic markets being pushed by EU regs just look at the arse kicking the EU just got over its rules against farmers. We dont know what development has been lost and costs inflicted due to higher regs.
"This was bureaucracy entirely of the UK's making and it affects just the GB market."
Thats the insanity of appeasing the scum during negotiations. This could have easily been resolved if May didnt try to keep us half in half out to appease both sides
Re the kettle: yes, on the face of it it is daft. Is it actually a thing or just a proposal?
But I always wondered if the Brits would along with it because it would smooth the corrie-st-ad-break-cup-of-tea electricity demand spike. Which was (is?) a thing.
But I can’t imagine that being an issue for any other eu country, and presumably it is dropping off here as the use of streaming services increases.
@I am David Jones
"Re the kettle: yes, on the face of it it is daft. Is it actually a thing or just a proposal?"
I am not certain but I think the stupidity died when we left. It was too easy fodder to demonstrate the state of governance from the EU.
"But I can’t imagine that being an issue for any other eu country"
That is actually a solid argument for leave. In fact one of the primary reasons
Good lord, that article is nonsense from start to finish.
If you're not liking that, here is some more Brexit nonsense for your delectation:
Canada contradicts Kemi Badenoch's claim post-Brexit trade talks are 'ongoing'
Just one of many examples of abject brexit/brexiteer failure.
@AC
"Just one of many examples of abject brexit/brexiteer failure."
I wasnt gonna feed the troll but others may read this and also believe this. This is not a failure of brexit but success. Regardless of your opinion of the governments stance on this deal they can walk away from it, because it is the UK negotiating a deal for the UK.
In the EU the competency of trade deals was the EU and the EU ass negotiating for 27 countries with conflicting economic interests. Due to brexit the EU decided all members must unanimously agree on the next trade deal, which was then held up by *not even a country*. What back room deals and brown envelopes were needed we dont know to get that final agreement.
No, reducing the power of electric kettles was never suggested in any EU consultation or legislation. It was a fiction created by the UK right-wing press, one contributor being Stephen Johns in the Daily Mail.
Of course the idea of it would be daft, anyone with a bare passing grade in O-level physics can see that. The people whom the EU commissioned to study electrical appliance efficiency were not barely-passing O-level students, they were engineers and scientists with Masters' degrees and PhDs, and they never suggested such an idea. In fact if you read the original Stephen Johns article, he doesn't actually say that they did. He just sort-of implies it. That his readers chose to believe this nonsensical fiction speaks to the blindness of their prejudices.
@I am the liquor
"No, reducing the power of electric kettles was never suggested in any EU consultation or legislation. It was a fiction created by the UK right-wing press, one contributor being Stephen Johns in the Daily Mail."
Is it maybe possible that it was suggested? Maybe by the European Commission? Maybe according to one the EU's very own?
https://www.reuters.com/article/us-eu-energy-idUSKBN1331Q5/
The European Commission has identified six types of electrical products where it wants to see lower energy consumption in order to help meet Europe's climate goals, among them kettles and hand dryers, Vice President Frans Timmermans said on Tuesday.
"What we are doing is evidence-based. We want to put the products on the list that have the highest energy yield. That is why kettles are on the list, because they are very high in terms of energy yields, and toasters are not on the list," Timmermans added.
Even the pro-EU Full fact report it-
https://fullfact.org/europe/first-they-came-vacuum-cleaners-will-it-be-kettles-next/
"Of course the idea of it would be daft, anyone with a bare passing grade in O-level physics can see that"
Thank you, yes, I agree, as did leave voters, some of which still get a kick out of the classics. I do like how derogatory your comment is about the idea because I too agree, except it wasnt some right wing conspiracy or prejudice but the truth coming from the Brussels horses mouth
@I am the liquor
"yes, they came up with all sorts of ideas about how to reduce the energy consumption of kettles. You do understand the difference between energy and power, don't you?"
Again, it takes a given amount of power/energy to boil a kettle. Why you think being pedantic is gonna change this I dont know (maybe you will explain?). We have so far come to the conclusion such a proposal is stupid (you and GStern so far) and both you and GStern didnt think the EU stupid enough to consider such a thing. And yet they did. So yes it would be a stupid rule and good fodder for brexit supporters as the EU was considering it.
Again, it takes a given amount of power/energy to boil a kettle.
Someone is digging themselves a big hole wrt their understanding of power/energy.
They did not. You've read the European Commission's study on the matter? No, of course you haven't. You've read the Daily Mail's lies about that study, and chosen to believe them, despite the fact that those lies should have been quite transparent, for the reasons already explained.
@I am the liquor
"They did not"
They did not what?
"You've read the European Commission's study on the matter? No, of course you haven't. You've read the Daily Mail's lies about that study, and chosen to believe them, despite the fact that those lies should have been quite transparent, for the reasons already explained."
Erm... did you read my comment? Granted its not the study I quoted but reuters and full fact which were quoting Vice President Frans Timmermans the Executive Vice President of the European Commission.
*edit: wernt you going to explain how I somehow got the power/energy thing wrong or was I right and it doesnt matter now?
They did not do the thing that about which you claimed "And yet they did."
The Reuters article does not say the EU wanted to limit the power output of kettles, it says that some people fear that. The Full Fact article is not terribly well written, but it is saying that not all of the 29 product categories would be regulated based on power output.
It takes a fixed amount of energy to boil a quantity of water. Reducing the power used does not change that; if anything, energy losses would be greater. The EU wants to reduce the energy consumption of appliances. Reducing the power consumption of a kettle would be counter to that goal, so they would not and did not consider that.
@I am the liquor
"They did not do the thing that about which you claimed "And yet they did.""
I said "both you and GStern didnt think the EU stupid enough to consider such a thing. And yet they did.". According to Frans Timmermans the Executive Vice President of the European Commission they actually did consider it. So you are saying the EU didnt consider what Executive Vice President of the European Commission Frans Timmermans claims they did?
"The Reuters article does not say the EU wanted to limit the power output of kettles, it says that some people fear that."
You either lie or didnt read it. I quote the article as I did before for you-
The European Commission has identified six types of electrical products where it wants to see lower energy consumption in order to help meet Europe's climate goals, among them kettles and hand dryers, Vice President Frans Timmermans said on Tuesday.
"What we are doing is evidence-based. We want to put the products on the list that have the highest energy yield. That is why kettles are on the list, because they are very high in terms of energy yields, and toasters are not on the list," Timmermans added.
"The Full Fact article is not terribly well written, but it is saying that not all of the 29 product categories would be regulated based on power output."
I think maybe you have moved the goal posts which might be where you are getting this wrong. The EU considered making such a change, I didnt say they did it. I quote myself responding to I am David Jones above-
@I am David Jones
"Re the kettle: yes, on the face of it it is daft. Is it actually a thing or just a proposal?"
I am not certain but I think the stupidity died when we left. It was too easy fodder to demonstrate the state of governance from the EU.
"It takes a fixed amount of energy to boil a quantity of water. Reducing the power used does not change that; if anything, energy losses would be greater. The EU wants to reduce the energy consumption of appliances. Reducing the power consumption of a kettle would be counter to that goal, so they would not and did not consider that."
And this is where I think you want your cake and eat it. This paragraph suggests you understand the stupidity, but then you claim (against Executive Vice President of the European Commission Frans Timmermans) that the EU would not and did not consider it.
Do you really think the European Commission doesn't have access to scientists and engineers who would spot a law if it was as daft as you present the kettle issue? has it not occurred to you that maybe there was a good reason for the proposal, which you have not spotted? of course, nationalist media in the UK (The Express; The Mail; The Telegraph) would have presented the proposal in the usual way: "look how stupid Europeans are and how their stupidity will affect the British way of life".
Accept that Leave was dominated by lies.
How about the EU regulating bananas, which the Chief Clown loved some much? (made himself a reputation among anti-EU well before the vote with this). It's rubbish: international regs about size/shape of products have always existed, to avoid nasty surprises for importers. But it was a mess, with different definitions in different countries, so EU just defined some standards (without banning bent and small bananas if you still wanted to buy them).
@GStern
"Do you really think the European Commission doesn't have access to scientists and engineers who would spot a law if it was as daft as you present the kettle issue?"
No. Oddly I have about as much faith in them as other governments.
"has it not occurred to you that maybe there was a good reason for the proposal, which you have not spotted?"
So you start with they wouldnt be so stupid to do it. Then suggest maybe they know how to break the laws of physics.
"Accept that Leave was dominated by lies."
As remain was. Shockingly even with the tonne of FUD remain also had the government using the threat of the state against us.
"How about the EU regulating bananas"
Which was a true issue of making it a criminal offense with a fine and/or prison! The EU not defining new standards as you say but instead taking the existing into criminal law.
"Hardly post-Brexit UK being the master of its own destiny, rather just waiting and hoping that EU countries fumble the ball."
As carried out by the world leading ball fumblers.
Having written that it's just occurred to me that that might have been behind the whole thing. They're always going on about Britain being world leaders in whatever they realised that this was something in which they could really remonstrate they were world leaders.
When the UK was part of the EU we had some say in what EU laws were and they were not foreign laws because we were part of the EU.
Now we have no say over what EU laws are, they are foreign laws, we have to obey them to access the larger market and there is no point going to the expense of creating a separate product specialised for a small market.
Back in the early 70's I was driving into the EU with computerized EKG health industry products from the UK company I was working for and we were happy to comply with EU laws that stated what colours the AC power cable wires had to be, virtually nothing else we did was regulated.
Before BREXIT the EU liked us (my visits were popular), and once BREXIT occurred the UK had a significant influence in the EU. But now we're just a good example of how effective it is to be in the EU.
@Flocke Kroes
"When the UK was part of the EU we had some say in what EU laws were and they were not foreign laws because we were part of the EU."
And now they are foreign laws. Back then they were still foreign laws of an organisation we joined.
"Now we have no say over what EU laws are"
Should we have say in US law? China's laws? Other countries? Maybe we should invade some countries to enforce our laws?
"we have to obey them to access the larger market"
No we dont. We do as we wish. If some business needs to apply export laws they can. If domestic or export elsewhere they do things correctly for that.
The EU wants more regulation, the UK less,
Not exactly. Tories UK wants less regulation for multinational corporations, while burdening SMEs with as much regulation as they can.
This kind of shows it - big corporation with access to legal teams (which costs peanuts in comparison to their revenue), will safely ignore this guidance, while small business will spend time and money on it - becoming less competitive.
"The EU wants more regulation, the UK less, what is wrong with that and that is the point of brexit."
Part true. Not necessarily more or less. Just different.
The problem with stuff like this that is supplied globally is that it has to comply everywhere you do business (or maybe even just let people look at your content) - the EU, US, China....
There are already American websites that block people in the EU or the UK. I think this is where things will go - different products in different markets.
Most companies tend to prefer market access over Balkanisation and are, therefore, generally keen on seeing countries adopt existing legislation, even if it might restrict them. They know they'll still be able to lobby for liberalisation in the future in invariably secret trade negotiations.
While I do remember notices on some US websites a few years ago I don't recall having seen any the last couple. IIRC there was a bried period when GDPR applied in the EU and there was nothing equivalent in the US. Then California introduced it's own "I bet you can't believe it's not GDPR" and the Brussels effect went into force. In any case, if you're a publisher, third-party cookies are not your friends.
However, I do believe that some US residents in some states reportedly can't access some websites in other US states.
Last year, the UK hosted an AI Safety Summit in its big pitch for relevance in this burgeoning tech landscape.
In my opinion that was typical Sunak's daft idea to show that his useless government is doing something and to get a photo with Elon Moscow. His detached from reality brain probably thought it will help him with the dwindling polls.
The money will make the decision.
If you need to sell to EU or have data that has originated in EU then you'll end up complying with the EU regs anyway.
UK gov might want to flap around and make noises about being seperate from Europe and able to make our own rules (Brexit means Brexit and other such sweaty faced drivel) but business will make up its own mind and probably plump for the EU rules since it's likely to give them pretty much global scope through one compliance policy.
None of this will stop Big Tech from stealing data and doing what they like as usual.
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