U.S. employers can no longer take a U.S.-centric view of artificial intelligence (AI) and data compliance. In a previous insight, we examined the EU AI Act’s extraterritorial reach for U.S. employers and the steps they would need to consider taking to build AI governance.

This insight goes further, exploring how employers can harmonise compliance across state-level U.S. and Canadian AI employment laws, alongside the EU and UK regulatory positions.

Quick Hits

• Employers need to keep track of two diverging regulatory tracks: the EU AI Act, with transparency obligations enforceable as of August 2, 2026, and further high-risk AI restrictions from 2 December 2027; and the UK’s Data (Use and Access) Act 2025.
• The EU AI Act is a floor, not a ceiling: individual member states layer their own obligations on top.
• U.S. state-by-state AI related employment laws in Illinois, California, New York City, and Colorado are now active or taking effect through 2027, even with a nonregulatory approach at the federal level.
• Similar to the United States, Canada has a province-by-province approach to AI regulation. Quebec, in particular, has passed comprehensive privacy laws that specifically address automated decision-making technologies (ADMT) and the processing of personal information. Each province has a standalone human rights statute that, if violated, can lead to sanctions, and in some provinces, punitive damages in addition to general employment and privacy laws.
• A...

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