India
DPDP Rules including AI/automated processing notice
in forceRegulation: Digital Personal Data Protection Act 2023 - Rules notified 2025
Scope: Data fiduciaries (controllers) processing Indian residents' personal data
Affects: Any platform with Indian users; AI training on Indian-citizen data carries higher consent burden
Primary obligation: Notice in 22 official languages, consent management, breach notification within 72h, children's data heightened protections
Penalty band: Up to ₹2.5B (~$30M) per breach
Russian Federation
Personal data localization + processing transparency for AI
in forceRegulation: Federal Law 152-FZ on Personal Data + 2025 AI amendments
Scope: Operators processing personal data of Russian citizens
Affects: Any AI service training on or processing Russian citizens' personal data; cross-border data transfers regulated
Primary obligation: Localization of initial personal data collection in RF; AI processing notice; consent flows; cross-border transfer rules with FSIS list
Penalty band: Up to ₽18M for fortified-localization violations; AI-specific penalty schedule under development
European Union
GPAI (general-purpose AI) provider obligations take effect
in forceRegulation: EU AI Act (Regulation 2024/1689)
Scope: Providers of general-purpose AI models placed on EU market
Affects: OpenAI, Anthropic, Google, Meta, Mistral, AWS, Microsoft, every fine-tuner above the systemic-risk threshold
Primary obligation: Technical documentation, training-data summary, copyright policy, codes of practice. Systemic-risk models: additional evaluations, incident reporting, cybersecurity.
Penalty band: Up to €15M or 3% global annual turnover for non-systemic; €35M / 7% for serious cases
United Kingdom
Children's safety duties (highly-effective age verification + content controls)
in forceRegulation: Online Safety Act 2023 - children's safety
Scope: Services likely accessed by children
Affects: Sites with pornographic content, gambling, age-restricted UGC - must implement highly-effective age verification (HEAV); knock-on effect on AI age-estimation vendors
Primary obligation: Highly-effective age verification, content categorization, age-appropriate experiences
Penalty band: Up to £18M or 10% global revenue
United Kingdom
Illegal content risk assessment + safety duties
in forceRegulation: Online Safety Act 2023 - illegal content duties
Scope: User-to-user services and search services in scope of OSA
Affects: Social platforms, forums, comment systems, adult platforms with UGC, search engines
Primary obligation: Risk assessment, take-down, transparency reporting, content-moderation systems (often AI-augmented - qualifies for AI-system obligations downstream)
Penalty band: Up to £18M or 10% global revenue
European Union
Prohibited AI practices take effect
in forceRegulation: EU AI Act (Regulation 2024/1689)
Scope: All providers and deployers placing AI systems on the EU market or using outputs in EU
Affects: Anyone offering or using prohibited AI practices (subliminal manipulation, social scoring, biometric categorization on sensitive grounds, untargeted facial-recognition database scraping, emotion inference in workplace/education with exceptions)
Primary obligation: Cease prohibited practices
Penalty band: Up to €35M or 7% global annual turnover
Brazil
AI-system data processing transparency under LGPD
in forceRegulation: LGPD + ANPD AI guidance (Resolution CD/ANPD nº 24/2024)
Scope: AI systems processing Brazilian-resident personal data
Affects: Generative AI vendors offering services in Brazil; training-data sourcing transparency obligations
Primary obligation: DPIA for AI processing, automated-decision review right (LGPD Art. 20), legitimate-interest balancing test
Penalty band: Up to 2% Brazil revenue capped at R$50M per violation
Singapore
Updated voluntary framework + GenAI-specific guidance
voluntaryRegulation: Model AI Governance Framework v2.0 + AI Verify Foundation guidelines
Scope: All AI developers/deployers serving Singapore market
Affects: Voluntary but de-facto baseline; financial-services regulator (MAS) treats compliance as expected
Primary obligation: Risk management, transparency, robustness, GenAI-specific: hallucination management, data lineage, prompt safety, bias mitigation
Penalty band: Voluntary; non-compliance signals risk for sector regulators
United States - New York City
Annual bias audit for AEDTs in hiring
in forceRegulation: NYC Local Law 144 - Automated Employment Decision Tools
Scope: Employers and employment agencies using automated tools for hiring or promotion decisions for NYC-based roles
Affects: HR-tech vendors (Workday, SAP SuccessFactors, Greenhouse, Lever, etc.) and their customers operating in NYC
Primary obligation: Independent annual bias audit, summary publication, candidate notice with opt-out mechanism for the AI tool itself
Penalty band: $500 first violation, $1,500 per subsequent per day