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Comparison · 15 questions · 9 instruments

Laws compared

A cell records what a text requires of the parties it defines. It does not show that any developer falls within them, or complied.

What does each binding government instrument that addresses developers of frontier or general-purpose AI models say on the same questions? Each column is one instrument; each row is one question, worded so that it fits every instrument. The questions are Selekoa’s; an instrument’s own terms appear only in quotation marks. Some instruments address providers of services rather than developers, and the first row quotes the party each one defines.

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Question Q14Enforcer

Which public body enforces or supervises the duties?

Criterion: A named public body given power to enforce, supervise or penalise breaches of the duties compared here, quoted.

What the statuses mean
Stated
A passage of the instrument meets the question’s criterion as worded, however conditional or narrow its scope. The condition or scope is in the note.
Stated, partly
A passage has what the criterion asks for, but in a weaker form than the criterion’s own words: for example, a power (“may”) where the criterion asks for a duty (“shall”), or a duty without the deadline the question asks about.
Not found in the recorded search
No passage meeting the criterion was found. The cell lists the sections read, the search terms and every passage set aside, with the reason. It does not show that the instrument lacks such a provision elsewhere, or that no other law imposes one.
Does not apply
The question does not arise for this instrument, for the reason given (for example, there is no framework document whose publication could be asked about).

Four rules decide “partly” in borderline cases:

  1. An order to an agency to impose a duty counts as partly.
  2. Protection only by reference to another law counts as partly.
  3. “Without undue delay” counts as a stated deadline.
  4. Required security measures for model weights count as risk-management measures under Q03.

Every stated or partly cell quotes the instrument’s own text with its article, section or page; Chinese passages carry Selekoa’s working translation. Three cells give a paraphrase with its locator instead, and say so. A not-found cell lists the sections read, the terms searched and every passage set aside, with the reason.

Paraphrased with its locator, not quoted: quoting it would pass the source’s quotation limit, or the source’s length is not known.

Limits of this comparison
  • A cell records what the text requires of the parties it defines. It does not show that any named developer falls within them, or that anyone complied.
  • A not-found cell is bounded by its search: the sections read and the terms searched. Another provision, or another law, may still impose the duty.
  • The Code of Practice is a compliance route, not a law. Executive Order 14110 is revoked, and the BIS rule’s rescission was announced; each column shows its standing.
  • The table compares and does not rank. Statuses are not scores and are not to be summed.
  • Biological and chemical risk provisions are recorded at policy level only.
  • Dates keep their kind: adoption, signature, approval, publication, entry into force and application are different events. A computed date is marked as computed.
How we searched

The instruments started from those on the frameworks-and-law page. A column was kept where the instrument is binding, or is the AI Act’s stated means of compliance (the Code), and places duties on developers or providers of frontier or general-purpose AI models. Fifty other instruments on that page were set aside, each with its reason, in the research pack: proposed or vetoed texts, guidance and reports, voluntary commitments, binding texts that place no duty on developers, and one standard whose text was not retrieved (GB 45438-2025).

United Kingdom: within the searches made, no UK law or other binding instrument placing duties on developers of such models was located. This is not a finding that none exists. The 2024 King’s Speech announced an intent to legislate; the 2026 briefing notes contain none of the searched terms; the memoranda with developers state that they are not legally binding; and title searches of legislation.gov.uk for 2023 to 2026 found one instrument, which places a duty on the Information Commissioner.

Other US federal texts: as read, none places a binding duty on developers. Executive Order 14409 of 2 June 2026 provides for a voluntary access framework and says that its section 3 authorises no licensing requirement.

Not yet read: the Republic of Korea’s AI Basic Act, Japan’s AI Promotion Act (2025), China’s provisions on deep synthesis (2022) and on algorithm recommendation (2021), and Colorado SB 24-205 (2024). They are not in the dataset; a later pack starts with Korea.

Illinois: the act’s official website refused the preparer’s requests, and the Internet Archive reset the connections. The cross-family checker’s session saved the enacted text from an Internet Archive capture of the official PDF (2026-09-08), and the cells were drafted from that saved text. The two model families read the act independently and agreed on the status of 13 of 15 cells. The approval date rests on the checker’s copy of the official bill status record, which the preparer could not open; it is given as a paraphrase, labelled as that copy.

Texts were read in official copies: the EU texts through the Publications Office’s repository, because EUR-Lex returned empty responses; California SB 53 from the Legislative Counsel’s database file, because its website refused requests; New York’s chapters in the Senate print and the Assembly’s bill records, not the session laws; the Chinese measures in the gov.cn policy library. Six web pages served changed bytes between retrievals; every quotation still matched.

Roles: one model family (Claude) drafted the cells, audited 50 of them in a fresh context and adjudicated. A model from another family (GPT, through Codex) checked 122 items, answering 85 of them blind before seeing the drafted answers. Where it disagreed, its status was applied. One cell it disputed (Executive Order 14110, Q06) was settled as not found after its second pass. For Illinois the roles were reversed: the checker read the act first, blind, and the drafter then wrote all fifteen cells without seeing its answers. The maintainer decided the remaining questions, including the four rules for “partly” and Illinois Q05 (partly, as for California’s identical wording). No person has checked the cells against the texts.

European Union

  1. EU AI Act

    Stated

    • “The Commission may impose on providers of general-purpose AI models fines”

      Article 101(1), first subparagraph (part)

    • “The AI Office, after consulting the Board, may conduct evaluations of the general-purpose AI model concerned”

      Article 92(1), chapeau

    • “The Commission has exclusive competence as regards general-purpose AI models under Article 88 of that Regulation.”

      Recital (31)

    Note: Under Article 88(1) the Commission has exclusive powers to supervise and enforce Chapter V and entrusts these tasks to the AI Office; Articles 89 to 93 give the AI Office and Commission monitoring, information, evaluation and measure powers. The new Article 75(1) inserted by Regulation (EU) 2026/1744 concerns AI systems, not models, and is not used here.

    Inspect sources and checks: EU AI Act, Q14 Enforcer
  2. EU Code of Practice, Safety and Security

    Stated, partly

    • “to enable the AI Office to assess compliance of providers of general-purpose AI models who choose to rely on the Code”

      Objectives, point B (PDF p. 2)

    Note: The Chapter names the AI Office as the body that receives Frameworks, Model Reports and serious incident reports and that assesses compliance of providers relying on the Code, stated as an objective of the Code. The Code does not itself confer enforcement or penalty powers; those are in the AI Act (see the AI Act row). Search for the rest of the criterion: Whole text. Terms searched: “AI Office (will|may|shall)”, “enforce”, “penalt|fines?\b|sanction”. Passages read and not counted: Recitals, (d) (PDF p. 3): Information sent to the AI Office treated under Article 78 AI Act; confidentiality, not supervision.

    Inspect sources and checks: EU Code of Practice, Safety and Security, Q14 Enforcer

United States: states

  1. California SB 53

    Stated

    • “A civil penalty described in this section shall be recovered in a civil action brought only by the Attorney General.”

      SEC. 2, Bus. & Prof. Code § 22757.15(b)

    • “report any critical safety incident pertaining to one or more of its frontier models to the Office of Emergency Services within 15 days of discovering the critical safety incident.”

      SEC. 2, Bus. & Prof. Code § 22757.13(c)(1)

    Note: The Attorney General recovers civil penalties. The Office of Emergency Services receives incident reports and internal-use summaries, reviews incident reports (§ 22757.13(d)) and may designate equivalent federal standards (§ 22757.13(h)); no penalty power is given to it.

    Inspect sources and checks: California SB 53, Q14 Enforcer
  2. New York RAISE Act (As amended, Chapter 96 of 2026)

    Stated

    • Paraphrase: Section 1427(1) as re-added lets the attorney general sue in a civil action for the penalties.

      Bill text, § 2 (GBL § 1427(1) as re-added), p. 8, line 7

    • “the office may, after notice and hearing, levy civil”

      Bill text, § 2 (GBL § 1428(5) as re-added), p. 9, line 8

    Note: The attorney general brings civil actions for penalties under § 1427. “Office” is defined in § 1420(16) as an office within the department of financial services reporting to the superintendent; it receives incident reports and disclosure statements, levies penalties under § 1428(5), assesses developers for operating costs (§ 1428(4)) and may adopt rules (§ 1429).

    Inspect sources and checks: New York RAISE Act (As amended, Chapter 96 of 2026), Q14 Enforcer
  3. New York RAISE Act (As signed, Chapter 699 of 2025)

    Stated

    • “The attorney general may bring a civil action”

      Proposed GBL § 1422(1), p. 5, line 1

    Note: The attorney general enforces through civil action. The division of homeland security and emergency services receives the protocol and incident disclosures alongside the attorney general (§ 1421(1)(c), (4)); no enforcement power is given to it.

    Inspect sources and checks: New York RAISE Act (As signed, Chapter 699 of 2025), Q14 Enforcer
  4. Illinois AI Safety Measures Act

    Stated

    • “A civil penalty described in this Section shall be recovered in a civil action brought exclusively by the Attorney General.”

      Section 25(b), first sentence, PDF p. 22

    • “the Agency may, after notice and hearing, levy civil penalties, fees, and costs”

      Section 18(e), PDF p. 19

    Note: The Attorney General recovers the Section 25 penalties. The Agency (the Illinois Emergency Management Agency and Office of Homeland Security) levies the Section 18 disclosure penalties, receives incident reports, audit reports and internal-use summaries with the Attorney General, reviews incident reports with the Attorney General (Section 15(d)) and designates equivalent federal standards (Section 17(a)).

    Inspect sources and checks: Illinois AI Safety Measures Act, Q14 Enforcer

China

These measures address providers of services, not developers as such.

  1. China, generative AI services (2023)

    Stated

    • “网信、发展改革、教育、科技、工业和信息化、公安、广播电视、新闻出版等部门”

      Working translation: the cyberspace, development and reform, education, science and technology, industry and information technology, public security, radio and television, press and publication and other departments

      Article 16 (第十六条), first paragraph

    Note: These departments strengthen the management of generative AI services 'according to their respective duties' (Article 16). Supervision and inspection (Article 19) and penalties (Article 21) are assigned to 'competent authorities' (有关主管部门) without further naming; Article 20 names the national cyberspace department (国家网信部门) for services provided from outside China.

    Inspect sources and checks: China, generative AI services (2023), Q14 Enforcer
  2. China, AI content labelling (2025)

    Stated

    • “由网信、电信、公安和广播电视等有关主管部门依据职责”

      Working translation: by the cyberspace, telecommunications, public security, radio and television and other competent authorities according to their duties

      Article 13 (第十三条)

    Note: The listed authorities deal with breaches according to their duties, under other laws and rules (see Q13).

    Inspect sources and checks: China, AI content labelling (2025), Q14 Enforcer

Revoked, or rescission announced

Kept as part of the record, each with its standing shown.

  1. US Executive Order 14110

    Stated, partly

    • “the Secretary of Commerce shall require:”

      Sec. 4.2(a), opening words, 88 FR 75197

    Note: The Secretary of Commerce is the body directed to require the reporting; the order gives no stated power to enforce or penalise breaches. Search for the rest of the criterion: Whole cached text of the Federal Register printing (88 FR 75191–75226), with close reading of Secs. 3, 4.1, 4.2, 12 and 13 and the signature block. Terms searched: “enforce”, “Secretary of Commerce”, “penalt”.

    Inspect sources and checks: US Executive Order 14110, Q14 Enforcer
  2. US BIS AI diffusion rule

    Stated

    • “cooperate with BIS’s auditing of records and facilities”

      Supplement No. 10 to part 748, para. 11, 90 FR 4566 (PDF p. 23)

    • “Failure to comply with BIS may result in revocation of VEU status”

      Supplement No. 10 to part 748, para. 11, 90 FR 4566 (PDF p. 23)

    • Paraphrase: The press release says that BIS has told its enforcement officials not to enforce the AI Diffusion Rule.

      BIS press release, 13 May 2025, para. 4

    Note: The Bureau of Industry and Security audits VEU records and facilities, may revoke VEU status and decides licence applications for 4E091 items (§ 742.6(b)(14)). The press release passage records an announced instruction on enforcement; it is not a provision of the rule.

    Inspect sources and checks: US BIS AI diffusion rule, Q14 Enforcer