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Henna Virkkunen told Axios at the G20 innovation ministerial that the US and the EU keep arriving at similar AI protections, Europe by regulating in advance and America through courts and state law. She made the argument at the summit where Washington launched the Carolina Principles urging governments not to create new AI rules or regulators.
Europe’s tech chief says the United States will end up with AI guardrails whatever this administration says about them. Henna Virkkunen told Axios in Chapel Hill that the two systems keep reaching similar places by different routes.
“The differences are not so big when we look at it in practice,” she said. “In Europe, we have regulation in advance, and in the USA they are often coming with the court cases.”
She made the argument at a summit where her host was making the opposite one. Michael Kratsios launched the Carolina Principles on 1 September, urging G20 governments not to build new AI rules or regulators, Al Jazeera reported.
Policymakers “should not treat every emerging technology as a first-of-its-kind policy problem“, Kratsios said. Elon Musk and Mark Zuckerberg appeared at the same ministerial.
Virkkunen’s answer is that America already has rules, just not federal ones. She counted hundreds of them at state level, before anyone reaches a courtroom.
The claim is testable, and the past week tests it.
On 31 August the Commission designated ChatGPT under the DSA as a very large online search engine, with Reddit and Roblox as platforms. All three have four months to comply.
The next day it sent its first requests for information to more than 30 AI providers under the AI Act. Commission spokesman Thomas Regnier said the questionnaires concerned mostly safety and copyright.
In America the comparable rules arrived through a courtroom. Meta settled with 51 attorneys general in August, agreeing to block teenagers overnight and cap them at two hours a day across Instagram and Facebook.
Virkkunen reads that as convergence, and it is. It also carries a price of $12.19B over ten years, for defaults European law expects platforms to work towards on their own.
The asymmetry runs the other way too. The unit inside the AI Office that evaluates frontier models is a team of 36.
Thirty-six people sending questionnaires to more than 30 companies, against 51 attorneys general and a settlement worth billions. Both produce rules, and they do not produce them at the same speed.
Movement is coming from the European side as well. Brussels agreed in May to thin out the AI Act, pushing high-risk obligations to December 2027, which may be part of why its tech chief can say the gap is small.
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